On December 22, 2010, the Federal Reserve Board issued an interim rule amendment clarifying certain aspects with respect to the Mortgage Disclosure Improvement Act (MDIA) changes that become effective on January 30, 2011. Here’s our 30 second overview. Unfortunately, this amendment does not push back the effective date for the January 30, 2011, MDIA requirements. You still have to comply with those requirements as of that date. What the amendment appears to do is revise, add to and/or further clarify the January 30, 2011, MDIA requirements.
The press release gives you two options. You can either comply with the January 30, 2011, requirements “as is” and apply the new amendments by October 1, 2011, or you can spend your Christmas and New Year’s break analyzing the October 1, 2011, amendment and comply with both as of January 30th. Your choice; however, my recommendation is the first option. We’d rather see you enjoy your holidays with your friends and family rather than reading Regulation Z changes!