What are your suggestions on what one should be doing with FACTA now? The regulatory and effective date schemes are complex. Do we have enough information on anything to start implementation activities?

I haven't heard anything yet. Personally I have just read the proposed language and mentally geared up for what is to come. From a seminar I attended a couple of weeks ago, it sounds like the final is going to be a lot like the proposed. It sounds like there is a little in there for almost every area of the bank....I'm just biding my time until the final comes out.

I would expect to see the first of a series of proposed rulemakings by the middle to the end of March given that several of the FACT provisions require final regulations to be in place by June - August. I also expect to see the proposed revisions to the old proposal for consumer opt-out that was proposed back in October of 2000 at the same time. Should make for an interesting summer and fall.

can you provide a link to the the text of FACTA?

Another Thread that has links

I heard yesterday that there may be as many as 20 regulations written to carry out the FACT Act.

I had some key managers sit in on a recent telephone briefing on the FACT Act. We brainstormed the major issues for our bank, and agreed that when the regs are published we'll kick the implementation plan into high gear. I think they appreciated the early 'heads up'.