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FRB
Proposes Guidance to Clarify Reg E
The
amendment to Reg E regarding overdraft charges to ATM and one-time
debit card transactions has raised many questions. The FRB has
received requests for further guidance in several specific areas of
the rule. Therefore, the FRB has issued a proposed rule and request
for comment on clarifications and guidance. The comment period was
brief and the mandatory compliance date of July 1, 2010, was not
extended.
Reg Z
Amended to Include Credit CARD Act Requirements Effective August 22nd
Yet another proposed rule has been issued to amend Reg Z.
This proposal pertains to changes that will be effective August 22,
2010, to implement additional provisions of the Credit
CARD Act. One requirement is to reevaluate at least every six
months the APRs increased on or after January 1, 2 009. This may
prove challenging for those who did not note the requirement in the Credit CARD Act and prepare policies and procedures to accomplish
this first review.
Gift
Cards: Final Rules Effective August 22nd
For
anyone who has ever purchased a gift card and later learned that
failure to use it could result in penalties that could eat away at
the funds, the gift card rule will provide relief. For financial
institutions it brings additional restrictions and adds another
amendment to Reg Z.
FRB
and FTC Issue Risk Based-Pricing Rules
A final rule has been issued that requires creditors to
provide a notice when credit is offered on material terms that are
materially less favorable. This is going to require a new way of
communicating with consumers. The rule is effective January 1, 2011.
Understanding
the Flow of ACH Information
The ACH system is a critical tool for the financial services
industry. For those who work with it daily, it seems logical and is
understood. For those who may work with it infrequently, it is
appears more complicated. And, the complication sometimes starts
with understanding the acronym “ACH.”
FinCEN
and OCC Assess Large CMPs on Wachovia
Due to its alleged willful failure to establish an AML program and
due to the consequences of that decision, including the laundering
of billions of dollars through its institution and failure to file
thousands of SARs, Wachovia has been assessed huge CMPs. $110
million will be forfeited to the U.S. government and $50 million
paid to the OCC. Sadly, Wachovia was apparently aware of its
shortcomings and took no action. When other institutions were
discontinuing work with casas de cambios, Wachovia continued and
expanded its services. In the end, it is paying the price.
Regulatory
Compliance Monitor Replaces ConclusionsOnline
Subscribers will soon see a new regulatory compliance website. The
new name will be Regulatory Compliance Monitor. Along with the new
look there will be new access credentials and additional
contributing writers will be added frequently.
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