With all the new regulatory changes it is hard to keep ones head on straight. This may be a stupid question, so forgive me.

If a final rule is issued and it does not say that it is issued by the "joint" agencies do all banks under different regulatory examiners need to comply? For example, the new rules regarding mortgage lender compensation under Regulation Z issued August was put out by the Board of Governers of the Federal Reserve System. If we are an OCC bank do we need to start taking action to comply?

You would have to look at the individual regulation to make that determination, but Regulation Z applies to all creditors regardless of by whom they may be regulated.

Okay, that would explain the difference between the SAFE Act which was new and the changes to Regulation Z. I swear these days sometimes I wonder if I have enough brains left for the job.

Thanks!