Does anyone know when we may be able to expect a ruling one way or the other on this proposed amendment? (adding exemptions for current MH's, streamlined refi's, and transactions under 25,000)
Good question -- There are a bunch of agencies that need to sign off on any such final rule. As of today, the FDIC has not posted a board meeting agenda for a November meeting. I'd look for a mention of the rule in the agenda once it is posted as a harbinger of approval.
I'm just guessing here -- the agencies may not be looking at this as a high-priority issue. They may just decide to wait until after the 1/18/14 effective date and tweak the rules after the fact.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
Reads Regs
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Joined: Nov 2004
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The FDIC Board met this morning and approved a final rule. It is 282 pages in non-Federal Register format. Here's a link to the agenda for the Board meeting. http://www.fdic.gov/news/board/2013/2013-12-10_notice.html It includes a link to the final rule. It is effective 1/18/14 and some alternative provisions regarding manufactured home loans are effective 7/18/15.
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
And there are separate parts of the document that amend the Fed's Reg Z (they still are keepers of Z for motor vehicle dealers) and the OCC, plus the updates to the Bureau's 1026.35 and Appendix N (a comma and two words are added there!). So the 282 pages is a comic book thickness compared with the 1888 page emanation from the Bureau a couple weeks ago.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8