Comment on Reg CC Proposal
The Federal Reserve Board has requested public comment on proposed amendments to Regulation CC (Availability of Funds and Collection of Checks).
The amendments encourage financial institutions to clear and return checks electronically, add provisions that govern electronic items cleared through the check-collection system, and shorten the “exception” hold periods on deposited funds. Submit comments by June 3, 2011.
The proposal will implement a provision in the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) to increase the current $100 next-day availability requirement for certain check deposits to $200 as of July 21, 2011, and make many other substantive changes to Reg CC.
To facilitate the financial services industry’s continuing transition to complete electronic check collection and return, the Fed is proposing amendments to:
The Fed also requests comments on whether it should consider future changes to Reg CC to improve the check collection system.
This includes changes such as decreasing the time a paying bank can decide whether to pay a check to reduce the risk to a depositary bank of having to make funds available for withdrawal before learning whether the deposited check has been returned unpaid.
Credit Score Disclosures
In March, the Fed and the Federal Trade Commission proposed regulations implementing the Dodd-Frank Act’s credit score disclosure requirements.
The statute requires creditors to disclose credit scores and related information to consumers in risk-based pricing and adverse action notices under the Fair Credit Reporting Act (FCRA) if a credit score was used to set the credit
terms or take adverse action.
Credit unions were just required to comply with new risk-based pricing regulations in January 2011. The proposed regulations would add two new model risk-
based pricing notices to reflect the following credit score disclosure requirements:
The Fed also proposed amending the Reg B (Equal Credit Opportunity) model notice that combines the adverse action notice requirements for both Regula-tion B and FCRA.
The proposed amendments would revise the model notices to incorporate the credit score disclosures described above.
The agencies want to have final rules and revised model forms in place by July 21, 2011.