When the FACT Act was passed it stated that the effective date for notifying a borrower that the lender was reporting negative information about a loan was December 2004. When the final rule was announced on June 8th, it indicated that the notifcation requirements were effective July 16. Is the effective date July 16 with a mandatory compliance date of December 4, 2004? Thanks.

I'm confused too! The way I read the June 15th Federal Register notice is that the Federal Reserve Board was required to create model notices and that language is effective on July 16th, but the banking regulators (FDIC, OTS, OCC & the Fed) are the ones that need to provide regulations addressing when the notices must be given and how they can be given. Once those regulators chime in on the how and when, then we have to being providing the notices by December.

Anybody agree with me?

I have the answer. I called and verified that the effective date is July 16 for using the model notices, but the mandatory compliance date is December 1, 2004.