Compliance Deadline for UGEA has been extended.

http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20091127a1.pdf

Well nice - now that everyone has already expended resources to send Reg GG notices to their commercial accounts before the initial 12/1/2009 deadline.

Between this and the "oops we didn't intend for the 21 day rule to cover ALL open-end accounts", it's going to be harder and harder to convince management to spend money to comply by these deadline dates.

ETA: Thanks for the heads-up Retread!

Ken called it!!

Now we will see if Congress can figure out what it wants to do with this fiasco.

I totally agree!! I have nothing nice to say right now, so I'll keep my mouth shut.

Nothing like waiting until the 59th minute of the 11th hour to put this on hold! Good gravy, they couldn't have done this a month ago? But on to the reason (besides complaining) for this post:

What is everyone planning to do to address this? Will you keep your program in place? Put it on hold and have your Board repeal the policy?

Although compliance with Reg GG is now optional until 6/1/2010, it's a good bet (yes, I know that pun's been used before) that Congress will do something with UIGEA between now and then. If you've started blocking authorizations for card-not-present gambling merchant transactions, I suggest you consider continuing to do so. If you have started vetting new business accounts to identify those that might have a higher risk of being involved in Internet gambling (legal or illegal), it might be a good idea to continue that, too, since it could be an indicator of higher risk for money laundering or other suspicious activity.

It could actually be a good thing to have a policy on whether you'll accept business accounts that involve Internet gambling, with or without UIGEA.

Then watch for developments in the coming months.

If you haven't yet notified your commercial customers of Reg GG compliance requirements, and haven't incorporated that notification and/or certification into your account documents/signature cards, delay any action on those items.

Since we have the policy approved by the Board already, we'll keep it in place. We'll also keep the Due Diligence part in place as well. If and when Congress/Regulators change anything we'll adapt at that time.

We are doing the same.

Magic City,
You must be talking about a different "Ken;" I did not call this one. My only acknowledgement to the possibility of delay was to suggest that banks word their policies and procedures to take effect on the actual effective date of the regulation, "as amended" without mentioning December 1, 2010.

The conclusion that banks need more time to prepare is refined cynicism. The only banks that need more time are those that made no effort. Since their gamble paid off this time, they will roll the dice again.

Bad precedent...

Ken
I really appreciate the wording you had suggested for the policy effective date because being proactive, we completed everything as required to meet the effective date. Since our policy has an no actual effective date, we are good whenever or if it goes into effect. Once again, you saved me time and trouble with your suggestion.

Thanks!

Reg GG should have no effect on the good folks raisng horses and dogs for racing. Should it?

If we have added this to our BSA policy:

On December 1, 2009, rules to implement the Unlawful Gambling Enforcement Act of 2006 (UIGEA) will be in effect. BANK has adopted the following procedures to comply with these rules in the areas of debit card transactions and new accounts opened for commercial entities.

What do you suggest we do?

Omega - no effect, unless they are also operating an on-line bookmaking operation.

burgh - the law is still effective, the mandatory compliance date has just been postponed.

I wonder where this will leave TVG?

www.tvgnetwork.com

They operate a website to accept bets for horseracing under separate state licenses. Presumably, they give each state a cut of the action just like they do at the track.