News and Recent Regulatory Updates

July 21, 2011

We would like to wish the Dodd-Frank Act happy 1st birthday and a welcome to the CFPB!  Well not really, but I wanted to let you all know of some very important events that took place on the transfer date on Thursday (July 21st).

• Regulation CC rules go into effect for the $200 next day availability
• FCRA risk based pricing provisions for adverse action notices go into effect for the credit score disclosures being required on adverse action notices 
• Risk based pricing exception notices for denials DOES NOT satisfy this requirement
• Regulation Q is repealed and allows interest to be paid for corporate accounts
• Remember that certain disclosures must be made stating that the account may not qualify for the temporary unlimited interest program for non-interest bearing transaction accounts
• OTS is dissolved and the CFPB will begin the regulatory processes

Also, don’t forget SAFE Act comes into effect on July 30th!

Regulatory agencies announce tentative date for SAFE Act registration

The regulatory agencies announced that the tentative date for the registration system to accept entries into the database is expected to be around January 31, 2011.  The initial registration process will last six months.

FDIC issues overdraft "guidance"

On November 24, 2010, the FDIC issued its anticipated guidance for overdraft protection programs.  Bankers Assurance was a featured article in the December 2010 The Arkansas Banker magazine regarding the changes.

December 2010 overdraft article

Articles

Recent published articles from Bankers Assurance, LLC

 The Continuing Evolution of Overdraft Protection Programs- December 2010 issue of The Arkansas Banker magazine.

The New Reality of Overdraft Services - March 2010 issue of The Arkansas Banker magazine

Upcoming Events

Speaking Engagements

None scheduled

Previous Events

• Shaun Harms conducted a webinar for the Arkansas Bankers Association regarding the FDIC and OCC overdraft guidance in June 2011.
• Shaun Harms was a featured speaker at the 2011 Arkansas Bankers Association's Compliance Conference in April 2011.
• Shaun Harms was a featured speaker at the 2011 Arkansas Bankers Association's BSA Conference in March 2011.
• Overdraft Webinar (Arkansas Bankers Association) conducted by Shaun Harms December 22, 2010

• RESPA Webinar (Arkansas Bankers Association) conducted by Shaun Harms August 19, 2010
• Shaun Harms and Donna Kelly were featured speakers at the 2010 Arkansas Bankers Association's BSA/AML Conference in Little Rock (January 2010).
• Truth in Lending seminar (Arkansas Bankers Association) conducted by Shaun Harms November 2009 (3 sessions).