Keeping Score

An interesting statistic is one concerning the banking industry and regulations. In the last four years, the financial institutions have been hit with ten major changes. And there are more to come this year. Consider what these have done to complicate your lives . . .

The Expedited Funds Availability Act-requiring funds to be made available according to a mandated schedule. How many meetings and training sessions, not to mention material, disclosures, postage and system changes have you dedicated to this since 1988?

The Competitive Equality Banking Act-covering the limitation on the maximum interest rate that may apply to mortgages.

The Fair Credit and Charge Card Disclosure Act-creating even more disclosures on or with credit card applications (to add to those already not read by customers).

The Home Equity Loan Consumer Protection Act-imposing additional restrictions, expanding the disclosures in advertising, applications and on loan documents.

The Women's Business Ownership Act-new to you? This one hasn't had too much publicity, but it requires additional disclosures of business credit applications and longer record retention.

Americans with Disabilities Act-first part takes effect on January 26, 1992. It prohibits discrimination against people with disabilities in areas of public accommodation-such as your ATMs and branch offices.

CRA amendments-is there a banker in the United States who is not aware of the requirements of this-other than yesterday's new hires?

HMDA Amendments-in FIRREA-expands required data from applications to data on turn-downs as well as loans made. Also under FIRREA, a requirement to use only state licensed appraisers.

Real Estate Settlement Procedures Act Amendments-an amendment affecting disclosure requirements of portions of mortgage escrow accounts and regarding information on selling loan servicing.

A requirement for financial institutions to mail notices of changes in FDIC coverage, in accordance with FIRREA.

Looking Ahead
And we are of the opinion that it's not over yet. In with, or separate from-makes no difference. Yet to come is the Truth in Savings Act, which will probably be dropped on the industry this fall. (Reg DD?)

Stay tuned. . . .

Copyright © 1991 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 2, No. 9, 11/91