Which is the CDD Due Date

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Question:

There were two dates in the Federal Register announcement of this new rule, a July 11, 2016 “effective date” and a May 11, 2018 “applicability date”. Which one do we follow?

Answer:

Banks “must” comply with the requirements from the new rule no later than May 11, 2018 and this is when the first examination on the new rule will start. However, remember that much of the new rule contains current regulatory guidance which examiners continue to utilize in exam reports and enforcement actions.
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