From the editor's desk: Have We Finally Reached "Overload"?

It's countdown time to Check 21 in our industry, and I'm observing a phenomena I never seen since I entered the banking industry 34 years ago. There are just seven months before Check 21 goes into effect, and three of those seven are vacation months, when employees are often gone for weeks at a time. Check 21, as the Check Clearing for the 21st Century Act is fondly called, will affect almost every part of your financial institution - as we've been telling you for the last three or four months. (See "Banks Gearing Up For Check 21 - Huge Operational Changes Anticipated" in the last issue, and "Study Shows - Banks Not Prepared for Check 21" in the issue before that and "Depositor Dilemma - Dealing with the Check Clearing for the 21st Century Act" in the issue before that!) Worse than that, this regulation and its results will affect your customers just as much - which means you'll have double the explanation/adjustment/learning process to handle.

And what have you done/learned/communicated so far about Check 21?

If you're anything like the bankers I've been talking to lately, the answer is, "Not much!"

It's hard to believe we're being so laid back about this. And I can see some real hustling going on as we get down to the wire.If you had to put a reason on it, we've just been so doggone piled up with earth shattering, system-changing, complicated, incomplete regulations lately that we've finally reached overload. We aren't to the point that we're saying we won't do it. We're just saying, "Oh, well - here comes another one - I'll get to it when I get to it."

I sometimes get requests to talk to banking organizations in less-than-formal settings, such as after dinner speeches or breakfast meetings or the like. Invariably the request will be to please update the regulations and changes so we'll learn something, but "...could you please make it entertaining, too?" Oh, sure. Try to do a stand-up comedy routine on the Patriot Act! I titled one such presentation, "The Patriot Act, Privacy Act and Check 21 - Banking's WMDs".

For the past couple of months, when I do these speeches, or do any training on Check 21, I offer $5 to anyone who can tell me what acronyms like IRD* and CTA* mean. I'm still carrying around the same $5 bill I started with in December.

Some of you have already started getting IRDs, and are telling me they're already creating customer adjada. Those of you that went to imaging on your statements - remember the hoopla and complaints you got when your customers got those statements? You ain't seen nuthin' yet!

It's going to get worse as the time grows shorter. BANKERS' HOTLINE will do what we can to help. But for goodness sake, training officers - compliance officers - keep an eye on the calendar!

*IRD - Image Replacement Document
*CTA - Check Truncation Act

Copyright © 2004 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 14, No. 1, 3/05