A Quick Look Toward 2010
Posted by Anthony Demangone
When I was a young lad, I realized that I would graduate from high school in 1990.  1990!  That date seemed like something from a science fiction movie.  Twenty years later, I still get those same feelings each year.  2010?  It can't be.  But it is.  And it will take me about a month to remember to write 2010 on my checks.
With that in mind, here's a quick run-down on things that we should keep in mind this year.
SAFE Act. Â If you are a state or federally-chartered credit union, there's still no news here. Â NCUA has yet to issue a final rule. Â And the deadline for registration is still 180 days after the system starts accepting registrations.
Escrowing. Â I'm not even sure if that is a valid verb. Â But we'll start doing that for higher-priced mortgage loans this April. Â And for manufactured homes, the escrow deadline is in October.
BSA. Â The BSA manual will be updated at some point. Â I'm not sure when, but it very well may require you to tweak your BSA/AML program. The CARD Act will require Treasury to issue rules to bring stored value cards under the BSA regulatory system. Â I expect that rule at some point.Â
Reg Z. Ugh. Â Â Where do I begin? Â Sure - we have a good grasp on how the open-end changes will wreck our social lives this year. Â But don't forget that there the July 1 changes to Reg Z's open end rules that already were to take affect before the CARD Act entered our lives. Â Also, there are proposals on HELOCs and closed-end lending that should go final this year. Â The private student lending rule takes effect in February. Â And the mortgage transfer/sale rule kicks in later this month. Â In addition, there are two more Credit CARD Act provisions that will become affective this August. Â The Fed will need to issue rules for those this year.
Reg E. Â The overdraft rules kick in on July 1, 2010. Â We expect additional guidance from the Fed this month on this topic.
FCRA. Â Risked-based pricing notice rules kick in on January 1, 2011. But don't forget that another "FACT Act rule" kicks in on July 1, 2010 - the Accuracy and Integrity Guidelines.Â
Corporates. Â NCUA has a major proposal out there to overhaul the corporate credit union system. Â NAFCU members - we urge you to respond to our Regulatory Alert's call for comments on this proposal.
Reg CC. Â The Fed has not officially changed the regulation due to the impending death of non-local checks. Â But they'll have to do so at some point in 2010.
The Hill.  Reg Reform and overdraft protection issues are addressed in a number of areas. But nothing has passed both houses.  Stay tuned.
So, 2009 was a bear. Â I'm not sure what animal 2010 will ultimately be, but it won't be a kitten.Â