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January 19, 2012



Question - hope it's not too late to ask! - How does CFPB get to call 12 CFR 1004 Regulation D —ALTERNATIVE MORTGAGE TRANSACTION PARITY ?? I thought Reg D would always have to be RESERVE REQUIREMENTS OF DEPOSITORY INSTITUTIONS. What am I missing?

Steve Van Beek

Unfortunately, regulators often operate in silos and don't necessarily take into consideration the actions of other regulators.

You would think they'd understand the confusion of naming two banking regulations as "Regulation D." I wish there was a better answer, but it looks like we are stuck with the confusion.


"Thus, if there is a rule change to Regulation CC, for example, it would come from the Federal Reserve."

Regulation CC implements both the Expedited Funds Availability Act and the Check 21 Act. The Dodd-Frank Act provided joint rulemaking authority to the Board and the CFPB for the EFAA's consumer protection sections and requires them consult with the OCC, FDIC and NCUA on proposed rules. See DFA 1086. Otherwise, Reg. CC rulemaking is exclusively with the Board.

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