Jan94
Platinum Poster
Joined: Mar 2001
Posts: 828
USA
My understanding is that it is supposed to be 6 months after the national directory is in place. The directory is not yet in place. The regulatory agencies are to publish something when it is ready.
What have I missed? What makes you think your regulatory agencies have the option to opt out of the Act? I can see where as Federal agencies they may have the option to opt out of any state requirement but not the Act itself.
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The opinions expressed are mine and they are not to be taken as legal advice.
I pulled the draft rule from the FFIEC website FAQ and it appears that the draft rule (already approved by the FDIC) is written as though all of the agencies will adopt it.
Per the Q&A, the rule is currently under review at the OMB, and once approved by the OMB, it is expected to be published by the agencies. My guess would be that everyone else will use whatever is approved by the OMB.
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.
I think this is just a case of the red tape progressing slowly.
Are y'all having withdrawals because you haven't had a new or revised reg in the last month? Needing something to do with your spare time?
Last edited by Andy Z; 03/12/1010:14 PM.
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
If we are a bank where our LOs are exempt from licensing, are we still suppose to have unique identifier numbers for our branches at this point? The application has a place for it.
As I understand it, we can't provide numbers we don't have. I think FannieMae have given extra time for those institutions that will register their lenders to comply with this rule.
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____________________________________ Keep Calm and Carry On CRCM