It is unlikely that any change to the rules will change the way in which you must obtain consent from the consumer. That's set out in either the UETA or E-Sign, whichever controls in your state. And if the Fed does anything, they're likely to loosen up some on the type of e-mail system you can use to send disclosures over. So, if you're willing to work with what appears to be the most restrictive set of rules likely, go for it. If you think the Fed's revised rule (if and when it arrives) will make life enough easier to warrant waiting, wait.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8