Thread Options
#1702813 - 05/24/12 01:32 PM H.R. 5691 to amend TIL
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
Not sure everyone is aware of this...because I wasn't! It was in a recent ICBA email. A proposal to amend TIL to include the overdraft programs.. http://www.gpo.gov/fdsys/pkg/BILLS-112hr5691ih/pdf/BILLS-112hr5691ih.pdf
_________________________
My opinion is mine only- not my employer's!


Return to Top
Lending Compliance
#1702821 - 05/24/12 01:38 PM Re: H.R. 5691 to amend TIL J2C
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,762
Bloomington, IN
I haven't seen this, nor read anything else about it.

When this "product" first came out 6 or 7 year ago there are several of us that predicted the product would eventually be brought in under the Reg Z umbrella therefore this action is no surprise to me.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#1702824 - 05/24/12 01:39 PM Re: H.R. 5691 to amend TIL Dan Persfull
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
I believe these proposed amendments are very similar to the OCC's proposed guidance on OD Programs that came out last year (or 2010) and were never finalized.
_________________________
My opinion is mine only- not my employer's!


Return to Top
#1702920 - 05/24/12 03:44 PM Re: H.R. 5691 to amend TIL J2C
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,485
On the Net
Dan my first bank offered this "program" before I started there in 1983. It has been around a long time but really gained popularity 10 years ago. I think the perceived regulatory abuses were discussed then and came into more regulatory control in your 6 or 7 year time frame.

I hadn't heard of this either and wonder what the chances are that it will pass in the House and the Senate?
_________________________
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

Return to Top

Moderator:  Andy_Z