The Interim Final Rules for Reporting Medical Information can be found here . It's 110 pages -happy reading!

Another 110 pages! Halleluiah!

This is totally ridiculous!

I guess I won't have any trouble staying awake tonight.

When I saw that the interim finals were available, I thought OK, maybe 20 -25 pages. How in the world can anyone write 110 pages on this topic? I was shocked. Don't know why I should be, been at this long enough to know better.

Regurgitation of comments, regs for each of the agencies effected, spacing, footnotes, etc...

Revised Reg. V here.

OK wait. I read this thing and am still confused. What are we supposed to do? Nothing. Since we do not use medical information in making a loan anyway?

It says Interim "Final" Rules, but states comments must be received within 30 days. Is this "final," or could the rules change based on comments received?

Because they are accepting comments it could change, but I don't believe that is likely. One thing that changed doesn't effect institutions as much as perhaps your affiliates. The exceptions under 411 applied to banks because our regulators were given rulemaking authority and they wrote them in. The FTC wasn't given this authority. But there are "institutions" under the FTC that are not under the banking regulators. They couldn't take advantage of the exceptions. So some definitional differences were made and I think that is a large part of why new comments are being accepted.

Can someone explain to me how or why a bank would use medical information when determining a loan. How does the bank even know any medical information on a borrower?

We have lawmakers holding one string, consumer interest groups holding another, and regulators holding yet another, and the bankers (compliance officers in particular) are dancing on the end of the puppet strings trying to make everyone happy. At the same time, the poor consumer is being inundated w/ disclosures, explanations and processes (which will most likely lead to an increase in fees), all the while muttering to anyone within earshot that all he wants is a simple loan to buy a house. I hate to take up space and time w/ this venting...BUT I'VE HAD ENOUGH!!! I'm going to sell Fudgy-Wudgy Bars on the beach

Quote:

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I'VE HAD ENOUGH!!! I'm going to sell Fudgy-Wudgy Bars on the beach

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I take it you haven't heard about the new Fudgy-Wudgy Bar disclosure (Regulation FW).

LOL!!!

That is still out for comment as the FDA wants a say because it is a food and they believe the disclosure should fit on a soup can. In Washington they're confused because they didn't know FW bars came in soup cans. NOAA believes the melt rate disclosure needs work because there is no national standard and the Beach Solicitors Association (BSA) believes a Know Your Chocolate Fudgy Wudgy Bar (KYC-FWB) is in order since they can vary. They believe in a risk-based disclosure and believe the fly by night companies such as Many Sold on the Beach (MSB) should be reported as Sorry A**ed Resellers (SARs) as they are responsible for lesser quality products, prompting this disclosure in the first place. Only certified resellers will be able to sell on the beach, but there is no certification program as of yet.

Facing this conundrum, Washington has decided instead that it is time to amend the FACT Act.

Then there is the disclaimer that must appear on all Fudgy Wudgy bars to attempt to prevent civil liability: "Eating Fudgy Wudgy bars may be hazardous to your health. Chocolate can be addicting and you may gain an inordinate amount of weight which will contribute to future heart attacks and obesity. Consult your doctor before eating any FW bars for genetically pre-disposed addiction markers and health risks."

The FACT act is being amended to prevent bankers from asking if you eat FW bars during the application process.

Andy and waldensouth............

STOP! PLEASE!! YOU'RE KILLING ME!!!

Har har har har. OK. No sit-ups necessary today. The laughing has completely worn me out.

Keep going....this stuff is great!

I merely wrote to vent...didn't realize that it was going to turn into Comedy Central. Glad it did, though. My day keeps getting better...first my app is denied for my chosen profession of FW Salesman (apparently bankers are under-qualified), and now I find out I'm named after a cat. The late, great Rodney Dangerfiled would be proud.

I have read section 222 relative to Medical Information and is it possible they are saying you have to make a loan to a terminally ill customer for longer than are going to live. Where is the Safety and Soundness in that credit decision? Just venting.

Fudgy Wudgy was a bar...
Fudgy Wudgy needs a SAR...