The Clearing House, jointly with the American Bankers Association, Consumer Bankers Association, Credit Union National Association, and National Association of Federally Insured Credit Unions, submitted a letter to the Board of Governors of the Federal Reserve System requesting an extension of the effective date for the recent final rule amending Regulation II (12 C.F.R. Part 235, the “Final Rule”). The letter explains that the Final Rule’s effective date of July 1, 2023 fails to take into consideration the implementation obstacles small issuers face and the impact on community banks and credit unions, which will be forced to rush implementation in a way that could jeopardize the safety and soundness of the implementation process and compromise the integrity and reliability of the ultimate result. The letter respectfully requested that the Board extend the effective date by one and a half years, to January 1, 2025, in order to protect consumers and the integrity of the U.S. payments system. The letter also acknowledged Governor Bowman’s dissent to the passage of the Final Rule and affirms the concerns she raised.
To read the full comment letter click here.