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2009 COMPLIANCE DATES
 
NOVEMBER 2009
11/02/2009 - Last day for TAG participants to opt out of extension of TAG program.
 
 
DECEMBER 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.
 
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.
 
2010 COMPLIANCE DATES
 
JANUARY 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.
 
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.)
 
 
FEBRUARY 2010
2/14/2010 Reg Z - Amendments revising the disclosure requirements for private education loan become mandatory.
 
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.
 
 
MARCH 2010
3/31/2010 TALF program expires -
 
3/31/2010 TALF - TALF program expires.
 
 
APRIL 2010
4/01/2010 Reg Z - Escrow on higher priced loans (Specifically, 12 CFR 226.35 (b)(3) is effective April 1, 2010).
 
 
JUNE 2010
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 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).
 
6/30/2010 TAG program expires. -
 
 
JULY 2010
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.
 
7/01/2010 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.
 
 
OCTOBER 2010
10/01/2010 Reg Z - Higher priced mortgage loan escrow for manufactured homes (See Reg Z changes for 4/1/2010)
 
 


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