Compliance Blog

Posted by Sarah Loats

There's quite a few compliance dates next year and the Federal Reserve sure seems to like July 1, 2010, as there are three fairly major rules effective that day. Let's recap, shall we (the links will take you to NAFCU's Final Regulation summaries):

1. Regulation Z open-end lending rules. Prior to the Credit CARD Act, the Federal Reserve issued final rules to the open-end lending rules. This was a major overhaul of the open-end lending rules, amending the rules for applications and solicitations, initial disclosures, periodic statements, and advertising, among other things.  For the changes that haven't been swallowed up by the Credit CARD Act, the effective date is still July 1, 2010.

2. FACT Act.  By July 1, 2010, credit unions must have in place policies and procedures regarding the accuracy and integrity of information provided to consumer reporting agencies.  This rule also addresses direct disputes from consumers.

3. Regulation E overdraft rules. This rule is probably fresh in your head, but again, the effective date is July 1, 2010.

As if that wasn't enough, we have quite a few more compliance dates coming up next year:

• RESPA - January 1.
• Truth in Savings (disclosures of overdraft fees on periodic statements and disclosure of account balances through automated systems) - January 1.
• Private Student Lending - February 14.  .
• Credit CARD Act - February 22.
• Reg GG - June 1.
• More Credit CARD Act (gift cards, reasonableness and proportionality of fees, reevaluation of credit card rate increases) - August 22.
• HELOC and closed-end mortgages amendments to Reg Z and SAFE Act registration requirements- who knows??? 

Maybe it's time to look into that year-long sabattical...