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#1295343 - 11/30/09 03:41 PM How do you feel about last minute changes/delays?
Mary Beth Guard Offline
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Mary Beth Guard
Joined: Oct 2000
Posts: 797
Oklahoma City, OK
When I read about the extension on the Internet Gambling reg on Friday, I couldn't help but think "This isn't regulatory burden relief when it comes during a holiday weekend before the Tuesday when compliance was to become mandatory."

This isn't the first time a compliance deadline has been extended or requirements have been changed or repealed at the 11th hour. How do you feel about it? Is it a good thing? Is it a bad thing?

My mental image is of the words "Procrastinators Rule!" being spraypainted on the side of buildings in Washington.

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#1295354 - 11/30/09 03:48 PM Re: How do you feel about last minute changes/delays? Mary Beth Guard
RR Joker Offline
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The Swamp
Frankly, it aggravates me to no end!
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#1295366 - 11/30/09 03:54 PM Re: How do you feel about last minute changes/delays? RR Joker
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I find it extremely frustrating as do my clients. Many are concerned that staff at the bank will read this as "we don't have to do this yet", making it much harder for the compliance department; the law wasn't changed, just the mandatory compliance date. Most banks I know were ready to go and had sent out their notices. This is not relief, it is a waste of banks' time and money which impacts their customers.

If they rescind the law eventually, or change the reg, more wasted time and money for all concerned.

A reality check in Washington is long overdue. They need to fully understand what their actions mean to banks.
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#1295370 - 11/30/09 03:58 PM Re: How do you feel about last minute changes/delays? Kathleen O. Blanchard
Nancyod Offline
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Joined: Nov 2008
Posts: 74
New England
I agree, if they were going to postpone implementation it should have been done sooner. At this late date, it makes us all feel like we just wasted time and resources that could have been utilized elsewhere.

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#1295375 - 11/30/09 04:03 PM Re: How do you feel about last minute changes/delays? Kathleen O. Blanchard
#Just Jay Online
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Cheeseheadland
Originally Posted By: MS Kaybee
I find it extremely frustrating as do my clients. Many are concerned that staff at the bank will read this as "we don't have to do this yet", making it much harder for the compliance department; the law wasn't changed, just the mandatory compliance date.


That was exactly the first email in my inbox this morning from Marketing: "so we scrape the mailing???"

grrrrr....
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#1295392 - 11/30/09 04:34 PM Re: How do you feel about last minute changes/delays? #Just Jay
Trees Offline
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I want to be reimbursed for programming costs as well as the notice which was already printed up and ready to be mailed out.
But, to be honest, I hope this badly written Reg just goes away quietly.

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#1295435 - 11/30/09 05:10 PM Re: How do you feel about last minute changes/delays? Trees
Georgia Plum
Unregistered

They are so busy cramming regs/laws for the sake of the consumer down our throats without thinking anything through that they don't realize all the negative impacts for consumers and banks. Then when the light bulb comes on, at the last minute they try and change everything, or put it on hold. I'M SICK OF IT!! We should be able to send a bill to the government for the cost of all their regulations.

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#1295489 - 11/30/09 05:42 PM Re: How do you feel about last minute changes/delays?
Rangers Fan Offline
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Joined: Dec 2001
Posts: 345
Yeah, like we aren't worried enough about ODP and RESPA for the holidays, now we have to go look to see if the date was on our statement stuffers....mine was not....WOOHOO!!!! Ya know, if we believe in the reg, we can kind of see why we need to do something, but when everyone was jumping up and down and screaming "Hey, you didn't even define what unlawful internet gambling was!!!!", I had a problem with this one to begin with. Guess this is as close to a Christmas gift to us that the Fed and Treasury can get since they can't figure out how to respond to things in a LOGICAL time frame....oh but Treasury can jump on the CFPA in a hurry....funny how that happens!

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#1295524 - 11/30/09 06:11 PM Re: How do you feel about last minute changes/delays? Rangers Fan
RebekahL CRCM Offline
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RebekahL CRCM
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Posts: 797
Big Sky Country
Frankly, after busting my tail to get the CCARD 21-day-billing-notice junk done in time last August, only to have Congress quietly say, "oops, sorry, we meant that just for credit cards" in NOVEMBER, I was in no crazed rush to get UIGEA stuff done. I had mostly finished, but we hadn't printed the notices yet.

You are right, all this late action praises procrastination and condemns proaction.

The kicker for me was reading Barney Frank's statement on the great gift he bestowed upon us in delaying UIGEA's implementation:

"The Department of the Treasury and the Federal Reserve Board of Governor’s deserve a great deal of credit for suspending these midnight regulations promulgated by the Bush administration which would curtail the freedom of Americans to use the internet as they choose and which would pose unrealistic burdens on the entire financial community,” said Congressman Frank. “This will give us a chance to act in an unhurried manner on my legislation to undo this regulatory excess by the Bush administration and to undo this ill-advised law."

Thank's for the swift relief, Senator, and thanks for leaving politics out of it... sick ...and don't even get me started on Frank and "regulatory excess"... mad
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#1295554 - 11/30/09 06:49 PM Re: How do you feel about last minute changes/delays? RebekahL CRCM
AuditorK Offline
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PA
Simply put, it ticks me off!

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#1295587 - 11/30/09 07:22 PM Re: How do you feel about last minute changes/delays? AuditorK
DeeQ Offline
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Turnpike Exit 10
It irritates me, too. I mean when you have tons of pending regulation and prioritize by effective due date and systems implications and they go and switch out like that, it really pi$$es me off.
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#1295633 - 11/30/09 07:56 PM Re: How do you feel about last minute changes/delays? DeeQ
The Minion Offline
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Calm down Deekles!! Your blood pressure is showing in your Avatar.
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#1295694 - 11/30/09 08:24 PM Re: How do you feel about last minute changes/delays? The Minion
Sinatra Fan Offline
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Sinatra Fan
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New Jersey
I'm really getting tired of the regulators and Congress taking the "ready-fire-aim" approach, because it's almost forcing us into a similar approach. It also hurts my credibility with the Board of Directors and other senior management, because they start thinking that I don't know what I'm talking about.
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#1295741 - 11/30/09 08:52 PM Re: How do you feel about last minute changes/delays? Sinatra Fan
AuditorK Offline
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PA
Originally Posted By: Sinatra Fan
they start thinking that I don't know what I'm talking about.


I'm getting that "look" too from senior management... frown

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#1295745 - 11/30/09 08:54 PM Re: How do you feel about last minute changes/delays? AuditorK
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,277
It truly is frustrating; nothing like making compliance even more difficult. It will make it harder to enforce deadlines going forward.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1295775 - 11/30/09 09:15 PM Re: How do you feel about last minute changes/delays? Mary Beth Guard
Patsy Cline Offline
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Patsy Cline
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Posts: 1,117
On the road...
Very frustrated! I work very hard to stay on top of everything that is happening in the world of compliance! Right now... not a very easy job! crazy Management has a hard time separating me (the compliance officer) from the message (all the changes)! You know... like it is all my fault! cry I like to be ahead of the game! I heard a senior officer say - "We need to drag our feet a little more often when it comes to compliance! It would save us the time and headache." mad
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#1295833 - 11/30/09 09:52 PM Re: How do you feel about last minute changes/delays? Patsy Cline
waldensouth Offline
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waldensouth
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Posts: 7,979
FINALLY ABOVE the gnat line
It will not make any difference to us. We've completed everything and are ready to implement. I wish they would quit wasting our time with regs they intend to rescind.
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#1295855 - 11/30/09 10:04 PM Re: How do you feel about last minute changes/delays? waldensouth
Lele Offline
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Lele
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Posts: 827
In the Sun
I am really 'fed-up' as my Mother used to say! What is with the last minute extension? Why-oh-why wouldn't they have planned this all out before announcing an effective date? We are in Compliance and notices and training are complete. This, to agree with others, makes me look like I do not know what I am talking about!
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#1295910 - 11/30/09 10:53 PM Re: How do you feel about last minute changes/delays? AuditorK
msboo Offline
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Posts: 260
AMEN! TO WHAT EVERYONE ELSE HAS POSTED....How frustrating to work so hard on one thing, which probably would have been a non-event in our small community bank anyway. This has taken away valuable time and effort away from my many other audit & compliance duties.

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#1296070 - 12/01/09 02:58 PM Re: How do you feel about last minute changes/delays? msboo
CalifDreamin Offline
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CalifDreamin
Joined: Mar 2002
Posts: 2,227
Far from Calif
Ditto what has been said already. No surprises in these responses. Also ditto what msboo stated - all of the changes taking place and what we have to do to prepare the bank and staff for them has taken me away from many other "normal" duties such as compliance reviews, etc. this year since I am a dept. of one. Frustrated and stressed seem to be the words of compliance officers for 2009.
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#1296404 - 12/01/09 06:31 PM Re: How do you feel about last minute changes/delays? CalifDreamin
kiemo Offline
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kiemo
Joined: Jan 2009
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MidUS
Ditto. Ditto. Ditto. especially Sinatra Fan. We mailed letters to all business accounts on Friday (27th) frown

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