Missouri Independent Bankers Association: Compliance Dates

12/31/2012	Extended Time Period Expires for The Helping Heroes Keep Their Homes Act of 2010 - Housing and Economic Recovery Act by The Helping Heroes Keep Their Homes Act of 2010- The provision for an extended time period (extended from 90 days to nine months) for protections affecting foreclosure, sale, or seizure of servicemembers' real or personal property expires.

6/30/2012	New Specifications for SAR/CTR Batch Filers - SAR/CTR batch filers must update their systems to the new specifications. All institutions that batch file the current CTR, CTR-C, SAR-DI, SAR-SF, SAR-MSB, or SAR-C will have to convert their systems to file the new CTR and SAR. FinCEN will make other filing technical specifications available in the near future.

3/15/2012	ATM Compliance - ATMs must comply with the communication requirements of the ADA and ABA Accessibility Guidelines for Buildings and Facilities.

1/31/2012	Final Rule- Employee Rights Workplace Notice - National Labor Relations Board's final rule requiring employers to post workplaces notices regarding employee rights regarding unions and collective bargaining. Notices are available at NLRB regional offices or on the NLRB website. Private sector employers subject to National Labor Relations Act must post the notice. The notice was originally required on 11.14.2011, but was delayed to allow for further education and outreach.

1/1/2012	Supplemental Guidance on Internet Banking Authentication - The FFIEC member agencies directed examiners to formally assess financial institutions under the enhanced expectations outlined in the supplemental guidance on Internet banking authentication beginning in January 2012.

12/31/2011	Paper Savings Bonds - Treasury ends over-the-counter sales of paper savings bonds, including sales through financial institutions and applications directly to the Fed.

11/14/2011	National Labor Relations Board's Final Rule - Requires employers to post workplaces notices regarding employee rights regarding unions and collective bargaining. Notices will be abailable at NLRB regional offices or on the NLRB website by October 1. Private sector employers subject to National Labor Relations Act must post the notice.

10/01/2011	Reg Z - Clarification of Reg. Z Credit Card Act and official staff commentary. Creditors may voluntarily comply sooner.

10/01/2011	Interim Final Rule - Allows for an upward adjustment of no more than 1 cent to an issuer's debit card interchange fee if the issuer develops and implements policies and procedures reasonably designed to achieve the fraud-prevention standards.

10/01/2011	Final Rule - Establishing standards (Regulation II) for debit card interchange fees and prohibiting network exclusivity arrangements and routing restrictions.

8/15/2011	Reg V Final Rules - Generally require a creditor to provide a risk-based pricing notice to a consumer when the creditor uses a consumer report to grant or extend credit to the consumer on material terms that are materially less favorable than the most favorable terms available to a substantial proportion of consumers from or through that creditor.

8/15/2011	Reg B - The Board amended model notices in Regulation B to include the disclosure of credit scores and related information if a credit score is used in taking adverse action.

7/22/2011	Reg Q Repeal - Effective date of the repeal of Reg. Q's prohibition on payment of interest on commercial checking accounts. A rule has been proposed to implement this.

7/21/2011	Reg Z and Reg M Amendments - The final rules amend Reg. Z and Reg. M (Consumer Leasing) to implement a provision of the Dodd-Frank Act, which requires Truth in Lending Act and the Consumer Leasing Act apply to consumer credit transactions and consumer leases up to $50,000, compared with $25,000 currently. This amount will be adjusted annually to reflect any increase in the consumer price index.

7/21/2011	Transfer - This is the transfer date when the CFPB will be vested with the consumer protection authorities currently held by the existing federal financial regulators, such as the Federal Reserve and the FDIC.

7/21/2011	Final Rule - The FDIC final rule repeals Reg. Q, the prohibition against the payment of interest on demand deposit accounts.

7/01/2011	FDIC Overdraft Payment Supervisory Guidance - The FDIC expects that any additional efforts to mitigate risk would be in place by July 1, 2011.

5/01/2011	Interim Final Rule - Implements statutory restricitions on the garnishment of Federal benefit payments and establishes procedures that finacial institutions must follow when they receive a garnishment order against an account holder who recieves certain types of Federal benefit payments by direct deposit.

4/01/2011	REG Z - Amendment to protect consumers in the mortgage market from unfair or abusive lending practices that can arise from certain loan originator comopensation practices.

4/01/2011	Final Rule Amending Reg Z - Increases from 1.5 to 2.5 percentage points the APR threshold for determining whether a jumbo mortgage secured by a first lien on a consumer's principal dwelling is a HPML for which an escrow account must be established.

4/01/2011	Fed's Final Rule Imposed by the Volcker Rule - Implement the conformance period during which banking entities and nonbank financial companies supervised by the Board must bring their activities and investments into compliance with the prohibitions and restrictions on proprietary trading and relationships with hedge funds and private equity funds imposed by the Volcker Rule.

4/01/2011	FDIC Final Rule on Assessments, Dividends, Assessment Base and Large Bank Pricing - This new large bank pricing system will result in higher assessment rates for banks with high-risk concentrations, less stable balance sheet liquidity, or potentially higher loss severity in the event of failure. Except as speciicially provided, the final rule will take effect for the quarter beginning April 1, 2011, and will be reflected in the June 30, 2011 fund balance and the invoices for assessments due September 30, 2011.

3/28/2011	FinCEN Final Rule - Amenda BSA regulations regarding reports of foreign financial accounts.

3/15/2011	Nondiscrimination on the Basis of Disability Final Rules - Effective dates of new ADA requirements for ATMs.

1/31/2011	REG E - The final rules prohibit dormancy, inactivity, and service fees on gift cards unless: (1) the consumer has not used the certificate or card for at least one year; (2) no more than one such fee is charged per month; and (3) the consumer is given clear and conspicuous disclosures about the fees. Expiration dates for funds underlying gift cards must be at least 5 years after the date of issuance, or 5 years after the date when funds were last loaded.

1/30/2011	Reg Z - The interim rule revising the disclosure requirements for closed-end mortgage loans is effective for all applications received on or after January 30, 2011.

1/03/2011	Official FDIC Sign - New FDIC signs must be posted showing the $250,000 minimum insurance amount.

1/01/2011	FACT Act - Generally require a creditor to provide a consumer with a notice when, based on the consumer's credit report, the creditor provides credi tot he consumer on less favorable terms than it provides to other consumers. Alternatively a creditor may provide such a consumer with a free credit score and information about their score.

1/01/2011	Reg Z - Final rule requiring purchaser or assignee that acquires loan to provide written disclosures within 30 days of sell, transfer or assignment.

12/31/2010	Unlimited Coverage for Noninterest-Bearing Transaction Accounts - This is the expiration date for the TAG program. However, the Dodd Frank Act extends this program for 2 calendar years and it applies to everyone as part of the standard FDIC coverage. For those who opted in, the original program does expire on this date. NOW customers must receive notice of expiration of TAG program. (On December 29, 2010, the President signed a law giving IOLTAs full coverage also.)

12/31/2010	Required Privacy Notices to Customers - The federal banking agencies published amendments to their rules that implement the privacy provisions of the Gramm-Leach-Bliley Act. The rules require financial institutions to provide initial and annual privacy notices to their customers. The Agencies adopted a model privacy form that financial institutions may rely on as a safe harbor to provide disclosures under the privacy rules.

12/21/2010	TAG Program - Expires 12/31/2010

12/10/2010	Final Interagency Appraisal and Evaluation Guidelines Effective -

10/01/2010	Reg Z - Higher priced mortgage loan escrow for manufactured homes (See Reg Z changes for 4/1/2010)

10/01/2010	Reg DD - Reg DD and the official staff commentary amended to address the application of the rule to retail sweep programs and the terminology for overdraft fee disclosures, and to make amendments that conform to the Board's final Regulation E amendments addressing overdraft services, adopted in November 2009

8/22/2010	Reg Z - Federal Reserve Board final rule to protect credit card users from unreasonable late payment and other penalty fees and to require credit card issuers to reconsider interest rate increases imposed since the beginning of 2009.

8/02/2010	Daylight Overdraft Posting Rules; - The Federal Reserve Banks will be offering an opt-in, same-day settlement service for certain ACH debit paymetns through the FedACH service effective August 2, 2010.

7/30/2010	TAG program expires. -

7/01/2010	Reg Z - Changes to open end credit early disclosures, periodic statements, more advance notice of change in terms, and increased advertising disclosures.

7/01/2010	Reg AA (Unfair or Deceptive Practices - A lender may not consider a credit card payment late unless statement is provided 21 days prior to due date. Requirements on how credit card payments above miniumum are allocated. Restriction on when credit card rates may change. Finance charges on previous billing cycles limited. Securitiy deposits and fees limited.

6/01/2010	Reg Z - Escrow on higher priced loans (Specially, 12 CFR 226.35(b)(3) is effective April 1, 2010).

6/01/2010	Reg E - The final rule limits the ability of a financial instituion to assess an overdraft fee for paying ATM and on-time debit card transactions that overdraw a consumer's account, unless the consumer affirmatively consents, or opts in, to the institution's payment of overdrafts for these transactions.

6/01/2010	Reg GG (Prohibition on Funding of Unlawful Internet Gambling) - Requires non-exempt participants in designed payment systems to establish and implement written policies and procedures that are reasonably designed to identify and block or otherwise prevent or prohibit unlawful Internet gambling transactions. Reg GG (extension of compliance date).

4/01/2010	Reg Z - Escrow on higher priced loans (Specifically, 12 CFR 226.35 (b)(3) is effective April 1, 2010).

3/31/2010	TALF program expires -

3/31/2010	TALF - TALF program expires.

2/22/2010	Reg Z - Amendments establish a number of new substantive and disclosure requirements pertaining to open-end consumer credit plans, including credit card accounts.

2/14/2010	Reg Z - Amendments revising the disclosure requirements for private education loan become mandatory.

1/19/2010	Reg Z - The purchaser or assignee that acquires a mortgage loan must provide the required disclosures in writing no later than 30 days after the date on which the loan is sold or otherwise transferred or assigned. (This rule was effective on 11/20/09 but compliance was optional until 1/19/2010.)

1/01/2010	Reg X (RESPA) - GFE and HUD-1 both change. Fee variance between GFE and HUD-1 limited based on fee type. Except with change of circumstances and new disclosures (within 3 business days of change), lender is locked into the fees originally disclosed for 10 business days after such disclosure.

1/01/2010	Reg DD (Truth-in-Savings) - Disclose overdraft fees for statement period and YTD on periodic statements. Balances on automated systems (e.g. ATMs) must not include overdraft protection amount.

1/01/2010	- Effective date of TAG participant opt-out.

1/01/2010	Reg S - Update the fees to be charged for producing records and takes account of recent advances in electronic document productions.

12/30/2009	Prepay Quarter Risk-Based FDIC Assessments - Prepay 2009 4th quarter and all of 2010, 2011 and 2012 on December 30, 2009 along with risk-based assessment for the third quarter of 2009.

12/01/2009	Reg GG (Unlawful Internet Gambling Act) - Must send required notice to existing customers. Must perform due diligence at account opening and have procedures for dealing with violations.

11/02/2009	- Last day for TAG participants to opt out of extension of TAG program.

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