Wednesday, May 20, 2009
I'll Be Offline For A Few Days
In the beginning of the second week in May, FRB published a final amendment to Reg Z effective for dwelling secured consumer loan applications as of June 30th, 2009. It also moved up some provisions from an earlier Reg Z amendment that were supposed to be effective October 1st.
In the tragic world of home loans, virtually no system can be reprogrammed in less than two months, and most of the provisions here have to do with timing of disclosures, and the timing of redisclosures, and the resulting waiting periods, and knotty topics such as the definition of "business days", and when a disclosure is deemed to have been received by a consumer.
It should not be so difficult as the bankers are finding it, but it is. To make matters worse, some very reputable compliance firms screwed up and have put the wrong information out there.
So.... I'll be busy for a few days making a thingie to handle it, because I am NOT spending the rest of my life answering questions about this.
If you know what I am discussing here, my deepest sympathies. I can't see why the Senate wanted to add the rule about carrying weapons in state parks to the credit card bill. Why don't do they something RELEVANT and add a federal RTKB workplace/training rule for compliance officers any time two different definitions of the same term are involved in the rules for one disclosure requirement? We all know that's about what it takes.