In a recent comment letter to FRB and CFPB, WBA voiced support for a recent proposal by the Agencies to use a calculation methodology for implementing a statutory requirement to adjust the dollar amounts in the EFA Act every five years.
In the proposal, the Agencies would release adjusted amounts in the first quarter of 2019 with an effective date of April 1, 2020, to provide appropriate time after issuance for implementation. Subsequent adjustments would be made every five years, with implementation occurring a reasonable period of time thereafter to allow for necessary changes to be made to an institution's systems, disclosures, etc.
WBA supports this proposal and expressed appreciation to the Agencies for acknowledging that frequent or abrupt changes to regulatory requirements cause challenges for institutions trying to stay in compliance.
The proposal from the Agencies also included a request for comment on a previously proposed amendment to Regulation CC from FRB which sought to reduce the period of time within which deposited funds may be held. WBA opposed this proposal when it was initially issued in 2011, and still opposes it today.