Congress Steps In

Regulatory compliance professionals hate ambiguity but work in a world that's full of ambiguity. How often do we hear "Are we in compliance"? How often do we have to respond "It depends", or "Maybe"? Certainty is not a luxury that we either get, nor do we necessarily strive for. If we had hard and fast rules to follow, we couldn't find creative, and legal, ways to comply with regulations. We do need to have some idea of what the rules will be, however.
Congress is making it impossible to even know what the rules might be even 3 months from now. As I last checked, at least three bills had been introduced regarding credit cards. Additionally, there is talk that a federal usury bill may be introduced which would amend TILA's definition of finance charge for purposes of determining whether a loan had an APR over the usury ceiling. I understand the legislative process is such that we may never see any of these bills passed and signed into law. What concerns me most is the three month implementation time contained in some of these bills. The need to make changes should not trump the need to make sure changes can be made in a timely fashion. If heroic measures are needed to ensure compliance, banks and credit unions will just pass on the cost to consumers. That's not reform, that's demagoguery