May You Live in Interesting Times
June 4, 2010
August 2, 2010
This wish is the first part of a fictional Chinese curse. The curse has three parts which become progressively worse. Living in interesting times would be an apt description of these last couple of years, and with the passing of the Financial Reform Act things will only get more interesting, at least as far as compliance is concerned. We are probably going to see an onslaught of regulatory changes unlike we ever seen before, or hopefully again.
Estimates state that we may see 243 or more new regulations coming out of the Act. A good many will not apply to our industry, but many will. We are going to see a new regulatory agency that will be establishing its own regulations which we will need to pay attention to.
There are some sections of the Act that credit unions really did not want to see. Can you say “Interchange”? But there are also a lot of good things to come. The $250,000 limit for NCUSIF is no longer temporary. It is permanent….but the “interesting” part is making sure you don’t have any of the old $100,000 signage up.
And then there are many sections we just are not sure about yet. This includes a provision that prohibits debit card issuers from restricting the number of payment card networks. In essence MasterCard networks could end up processing Visa cards or vice versa. How this is going to filter down to credit unions is still to be determined.
A few resources are already becoming available to keep abreast of the changes. The FDIC has launched a new webpage that is dedicated solely to the Financial Reform Act. The SEC has established a public comment page to received comments on proposed changes for the Financial Reform Act. There currently are comment forms available for each of the 31 proposed changes.
Keep checking our Focus articles. Both the Compliance Calendar and Legal Briefs are good sources of information regarding the regulatory landscape.
Of course we will continue to keep you informed of changes as they come out. Together we’ll get through these interesting times and avoid the second part of the curse: ”May you come to the attention of those in authority.”
I’ll leave you with the third part. “May you find what you are looking for.” Especially if what you are looking for is your car keys.
Posted in Compliance.