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#522863 - 03/28/06 02:11 PM What's not yet finalized?
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
I'm so confused! What parts of the FACT ACT are NOT yet finalized?

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#522864 - 03/28/06 02:48 PM Re: What's not yet finalized?
ToTo Offline
Platinum Poster
Joined: Apr 2004
Posts: 595
OZ
Here's my list:
Affiliate sharing (214);
Risk based pricing (311);
Accuracy guidelines (312)(Advance notice of proposed rulemaking published in the Federal Register on March 22, 2006);
Red Flag guidelines, including the address change and inactive account regulation (114).

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#522865 - 03/28/06 03:07 PM Re: What's not yet finalized?
PJ Offline
100 Club
Joined: Sep 2005
Posts: 115
This may also be helpful - if your institution is an ABA member, there is a status chart (last updated 3/13/06)
Status Chart

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#522866 - 03/28/06 03:38 PM Re: What's not yet finalized?
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
In addition to ToTo's list, I would add:

Reconciling addresses - Section 315

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#522867 - 03/28/06 03:52 PM Re: What's not yet finalized?
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
Thanks to both of you. Have a great day

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#522868 - 04/03/06 02:14 PM Re: What's not yet finalized?
SkyDiver Offline
Gold Star
SkyDiver
Joined: Jul 2002
Posts: 274
Northeast
This is driving me batty. Any street news on when affiliate sharing regulations will be finalized?

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#522869 - 09/29/06 03:25 PM Re: What's not yet finalized?
duplextx Offline
100 Club
duplextx
Joined: Oct 2002
Posts: 144
Dallas, TX
Have the joint agencies prescribed regulations providing guidance on policies & procedures for Section 315 - Reconciling Addresses as yet?
_________________________
This is the sort of stuff that makes "retirement" look oh-so-very attractive!

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#522870 - 09/29/06 08:27 PM Re: What's not yet finalized?
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
The proposed 315 address reconciliation regulations were issued together with the section 114 Red Flag regulations. The were in the Federal Register on July 18 and they accepted comments until September 18. Proposed regs

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#522871 - 10/03/06 09:10 PM Re: What's not yet finalized?
sgarza1979 Offline
New Poster
Joined: Oct 2006
Posts: 9
McAllen, TX
I too am confused as to what is finalized. We just had an audit and we recieved a write up for not having any formal procedures in place to ensure identity of a customer requesting credit if a fraud alert appears on the customer's credit report. The recommendation read, "To mitigate fraud risk and ensure the proper identity, formal procedures should be created and implemented. Procedures may include additional steps for identification, additional security questions, as well as additional documentation to evidence of proof." If the Red Flag Guidelines are not finalized yet, how can we still get written up for it? Should the recommended policies be in place already even though there has been no Final Rule released?
_________________________
Stephanie Garza
Compliance Auditor
Inter National Bank

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#522872 - 10/04/06 02:37 PM Re: What's not yet finalized?
MN Banker Offline
Platinum Poster
Joined: Aug 2006
Posts: 980
The provisions regarding fraud alerts are final, therefore you should have procedures in place to ensure you are in compliance with FACTA when extending credit to someone with a fraud alert.

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