I am struggling with CCARD provisions. We put in place compliance with the pieces that became effective in August. I understand that many provisions of the Act become effective February 22, 2010. And my understanding is that the Federal Reserve released its proposed rule in September with an expected release date of final rules in December. Have the final rules been released yet? How are we going to be sure we're in full compliance by February 22 if we don't get the final rules until December? Do I have things confused?

The lead time for implementation has shortened tremendously for several of the new regulations, so unfortunately the safest thing to do is to go through the proposals, get a sense of whether they're likely to be so controversial that they may change significantly, and GO AHEAD with preparing to implement the proposal.

With CCARD, the proposals and the final are likely to be very similar, in my opinion. So your best bet is to at least assess the scope of the changes and their probable resource requirements at your institution, and do whatever planning you can. Good luck!