While I appreciate all the differing points of view on who gets which disclosures and when it needs to be given and what this, that or the other posters regulator is saying, it is either time for an extension to be announced or the gurus need to combine all this talk into a plan of action for each finalized section that a reasonable Compliance Officer type person can understand! PLEASE?!

ALSO, can a guru please tell us exactly where the cutoffs are between what our CRAs must do (for the applicant/consumer) and what we must do (for them)?

Thanks!

(Pardon me while I RANT!)

I've never read so much confusion - it makes ones' head spin.

Me (probably) or this wonderful regulation?

I feel the same way, I have accumulated so much in my files on the Fact Act. First I am making sure we are in compliance with the Act and then trying to get my business units to write their procedures and implement them by 12-1-04!!

Very BIG TASK!!!!

not you- the Fact Act and all the extras- just wondering if anyone knows what they are doing

Yes, and with Thanksgiving in the middle of all this, even if I can figure out what to say in training, getting people together for training before 12/1 is a joke!

To disclose, or not to disclose, that is the question...
Well, actually there is also a question about WHAT to disclose...
Then again, there is a question about WHEN to disclose...
Oh yeah, and there's also a question about WHO to disclose to...
Oops, almost forgot the question about HOW to convince management about WHO, WHAT, WHEN, etc. when you don't know yourself?!

(There, I think that covers all the main interogatory query terms!)

I got so confused by all the webinars, articles and other various information that I've been getting on FACTA that I sat down for a few hours yesterday and re-read the final rule. It did eat up most of my day, but It really helped me get back on track to where I can see what needs to be done and prioritize the project a little better.

Probably the best course of action...when in doubt, read the regulation (I can't believe i just said that)....

Yes, when in doubt! With all the webinars, and updates have made it confusing, I too have went back to prioritize what needs to be done and when? Like I said as long as we are in Compliance with what goes into effect on 12/1/04 we should be covered.

The ABA sent a letter to the federal banking agencies requesting clear direction. That should take care of it. Yah right!!!

Ahh haaa! That assumes that the federal banking agencies, themselves, have a clue as to what they're doing with the new rules. Ok, boys, you clear that up and get back to us ASAP.

Fact # 1 - The FACT ACT is factless and that's a fact!!!

Fact # 2 - Who really cares about Fact # 1

Fact # 3 - FACTA spelled backwords is ATCAF (Can anyone tell me what this stands for?)

ATCAF - A Time Consuming Abosoulte Farce........

At Times Compliance Ain't Funny.....

ATCAF - All This Crap Ain't Funny...

Look out - OnTheEdge is on roll - (just stay on that edge and don't roll over it )

That is totally it!!!!!

THAT was awesome! Really..... that made my day. :-)

I better stop....The others I've come up with aren't fit to be posted here!!!

Me, NCMountainMan, not logged in. I saw that letter to and went, "Whew!" (NOT)

ATCAF equals:

Always Try Compliance AFTER the FACT!