Compliance Blog

May 06, 2009

Reg Z Open End Proposal; Reg CC

I think everyone has a friend who is just hard to keep up with.  They date a new person every week.  They move repeatedly.  They are always on to something new and exciting.  When you see that friend, you have to spend the first 15 minutes getting an update on their life.

I feel that way about Regulation Z.

Yesterday, the Fed released another proposed amendment to Regulation Z concerning its open-end rules.  You can access the proposed rule here.  Here's what they were trying to accomplish:

Since publication of the two rules, the Board has become aware that clarification is needed to resolve confusion regarding how institutions will comply with particular aspects of those rules. Accordingly, in order to provide guidance and facilitate compliance with the January 2009 Regulation Z Rule by the effective date, the Board proposes to amend portions of the regulations and the accompanying staff commentary. These proposed amendments are discussed in detail in Section III of this supplementary information. Similarly, elsewhere in today’s Federal Register, the Agencies have proposed to amend certain aspects of the January 2009 FTC Act Rule (FTC Act Proposed Clarifications). Although comment is requested on the proposed amendments, the Board emphasizes that the purpose of this rulemaking is to clarify and facilitate compliance with the consumer protections contained in the final rules, not to reconsider the need for—or the extent of—those protections. Thus, commenters are encouraged to limit their submissions accordingly.

To help you see the proposed changes, the Fed uses symbols.  Anything within bolded brackets [example] is getting whacked.  Anything inside bolded arrows is a proposed addition.

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The Federal Reserve keeps restructuring its check processing centers, and they keep amending Regulation CC to keep up with the changes.  Check out the latest here, whichaffects check processing in the 10th, 11th, and 12th districts.  In short:

The Federal Reserve Board has approved amendments to Appendix A of Regulation CC that reflect the restructuring of the Federal Reserve Banks' check-processing operations.

Appendix A provides a routing symbol guide that helps depository institutions determine the maximum permissible hold periods for most deposited checks. On June 20, 2009, the Reserve Banks will transfer the check-processing operations of the Seattle branch office of the Federal Reserve Bank of San Francisco to the Los Angeles branch office of that Reserve Bank. On June 27, 2009, the Reserve Banks will transfer the check-processing operations of the Denver branch office of the Federal Reserve Bank of Kansas City to the Los Angeles branch office and to the head office of the Federal Reserve Bank of Dallas. Effective June 20, 2009, the Board is amending the list of routing symbols in Appendix A associated with the Federal Reserve Bank of San Francisco to reflect the transfer of check-processing operations from Seattle to Los Angeles. Effective June 27, 2009, the Board is amending the lists of routing symbols in Appendix A associated with the Federal Reserve Banks of Kansas City, Dallas, and San Francisco to reflect the transfer of check-processing operations from Denver to Los Angeles and Dallas.