there were some gromblings a while back about this beauty. Anyone heard whether or not there are plans to postpone implementation??

There was talk, but we are too close to the date for anything to happen now, IMHO.

Have your items approved and in place by the first.

All I can tell you is our policy and processes are already a go.

ditto

Fo the Certification from the commercial customer that it does not engage in an Internet gambling business...What are you guys doing?

Is there a Model certification form? Is this something we create? Is it something the Customer is responsible for getting from elsewhere to provide us with a copy? Do any of you ahve something for the certification you are willing to share?

Thanks!

Can anyone tell me if the initital notice to the commercial customer has to be prior to December 1? If so, where is that in the Reg? Thanks

Can anyone tell me if the initial notice to the commercial customer has to be done before 12/01/09? If so, can you also tell me where this is in the Reg? Thanks

Federal Register:

http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20081112a1.pdf