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EBanking: FRB Issues E-Rules
The FRB has released interim rules on electronic disclosures for Regulations B, E, M, Z, and DD. These interim rules are in effect immediately. They therefore authorize banks to use electronic disclosures and give specific guidance on how those disclosures should be designed and delivered.
As interim rules, they are also open for comment. This continues the comment process that has been underway for several years. Comments on the interim rules are due by June 1, 2001. It appears that the Board expects to issue final electronic disclosure rules after receiving and considering this last set of comments.
Since the Board first began considering electronic disclosures, the technology has changed dramatically. Now, the interim rules are having to deal with display screens that may be very different from the typical computer monitor. Displays may be on Palm Pilots or even cell phone screens.
The content of the interim rules is reasonable and should be fairly easy to follow. The most important element to keep in mind is that the electronic disclosure rules, while permitting electronic disclosures, do not change any content and timing rules. To the extent possible, the Board has incorporated the existing timing rules. For example, if a paper disclosure must be "sent" by placing it in the mail, the comparable electronic disclosure may be "sent" under the same timing rule by hitting the appropriate computer key.
The interim rules also contain requirements for making disclosures available to the consumer on the bank's website. The rule specifies a period of time during which the disclosure must be available to the consumer. In addition, the bank would have to notify the consumer that the disclosure is available.
Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 6, No. 3, 4/01
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