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#626371 - 10/18/06 08:27 PM Reg E & Reg CC disclosures
Glendle Offline
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Joined: May 2006
Posts: 18
Can anyone tell me where in the regulation it states (or does it?) that the board actually has to approve these two disclosures / policies?

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Operations Compliance
#626372 - 10/18/06 09:05 PM Re: Reg E & Reg CC disclosures
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
It doesn't. It's a s t r e t c h to call any preprinted disclosure a "policy."

Please expand a little, has someone suggested you need a Reg E and a Reg CC policy?
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#626373 - 10/18/06 10:20 PM Re: Reg E & Reg CC disclosures
Glendle Offline
New Poster
Joined: May 2006
Posts: 18
Not exactly - I thought the Reg CC had to be approved by the board, and when I went looking could not find anything specific. The subject started when changes to existing practices trigger revised disclosures - and which ones would need to be 'approved' by the board. Thanks for responding.

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#626374 - 10/19/06 09:53 AM Re: Reg E & Reg CC disclosures
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There is no legal requirement for board approval on policies related to any topic routinely considered as a consumer protection law. Any policies you may have on consumer protection laws fall under the heading of a "good idea," but, out of necessity they would be very broad.

Changing a disclosure in connection with Regulation E or CC would not necessitate board approval unless it was a self imposed restriction required by your policy. Personally, I've always considered asking the board to vote on things they will not understand as an upward delegation of responsibility.

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