A Different Look at the Republished Regulations
Written by Steve Van Beek
With all the discussion of the CFPB's republishing of the consumer regulations, I thought it would be a good idea to also highlight some of the regulations that did notÂ transfer to the CFPB. Â
There are also quite a few Federal Reserve regulations that did not transfer to the CFPB. Â The rationale being that these regulations do not implement the "enumerated consumer laws" and, thus, didn't fall under the CFPB's authority. Â
Here is a list with links to some of the Federal Reserve regulations that did not transfer to the CFPB:
- Regulation D - Reserve Requirements of Depository Institutions - 12 CFR 204
- Regulation CC - Availability of Funds and Collection of Checks - 12 CFR 229
- Regulation GG - Unlawful Internet Gambling Enforcement Act (UIGEA) - 12 CFR 233
- Regulation II - Debit Card Interchange - 12 CFR 235Â
Keep in mind that the Federal Reserve retains control over these regulations. Â Thus, if there is a rule change to Regulation CC, for example, it would come from the Federal Reserve.
One of the gifts that Dodd-Frank gave to all credit unions is the need to look to anotherÂ regulator for regulatory changes. Â Which means we have anotherÂ regulator that, unfortunately, does not have the ability to view theÂ comprehensiveÂ regulatory burden put on credit unions by the various regulators.