.thumbnail.jpg "At the 2010 IBAT Asset Liability Management Summit")
Commenting on Transfer of Regulations
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IBAT Comments on CFPB’s Transfer of Regulations
As innocuous as a transfer of regulations from one federal agency to another may at first appear, we are concerned with the deleterious effect the transfer could have on compliance research. When Regulations B, C, E, F, G, H, I, J, K, L, M, O, P, X, V, Z and DD are transferred to the Consumer Financial Protection Bureau, does that mean that all the links we’ve made to the transferred rules will die overnight. The next time you are researching a compliance issue and you click on a link to read the law, that link may be dead. Our guess is that it will. Additionally, the numbering for all these regulations will also change overnight? For instance, Regulation Z will change from 12 CFR part 226 to 12 CFR 1026. This is going to cause a lot of confusion. Finally, transactions that occurred prior to December 30, 2011, will be regulated by the old regulations and those closed thereafter will be controlled by the new regulations.
IBAT has written a comment letter to the CFPB, and we encourage you to use it as a template to express your concerns to the CFPB.