ELECTRONIC DELIVERY OF CONSUMER PROTECTION DISCLOSURES
August 13, 2001
CHIEF EXECUTIVE OFFICER AND COMPLIANCE OFFICER
Lifting of Mandatory Compliance Date for
Interim Rules Amending Regulations B, E, M, Z, and DD
On August 3, 2001, the Federal Reserve Board (FRB) announced it had lifted the October 1, 2001, mandatory compliance date for interim rules governing the electronic delivery of certain consumer disclosures. Financial institutions and others covered by the rules identified operational issues raised by the requirements and requested more time to make needed changes. Based on the comments, the FRB announced it is considering adjustments to the rules to provide additional flexibility. Once permanent final rules are issued, the FRB expects to afford institutions a reasonable period of time to comply with those rules. A copy of the announcement is attached.
On March 30, 2001, and April 4, 2001, the FRB published interim final rules on electronic disclosures and invited public comment. The rules establish uniform standards for the electronic delivery of required disclosures under five consumer protection regulations: B (Equal Credit Opportunity), E (Electronic Fund Transfers), M (Consumer Leasing), Z (Truth in Lending), and DD (Truth in Savings). The interim rules implement provisions of the Electronic Signatures in Global and National Commerce Act (the "E-Sign Act") of 2000. These were transmitted to you in FIL-40-2001, dated May 11, 2001.
Even though the mandatory compliance date for the interim rules has been lifted, institutions may continue to provide electronic disclosures under their existing policies and practices or they may follow the interim rules until the FRB issues permanent rules, as long as the institution's procedures comply with the consumer consent requirements of Section 101(c) of the E-Sign Act.
For more information, please contact Eric L. Kooistra, Review Examiner in the FDIC's Division of Compliance and Consumer Affairs, at (202) 942-3339 (e-mail Ekooistra@fdic.gov).