Compliance Bulletins

State Bolsters Data Breach Notification Law

September 20, 2011

The state’s data breach notification law, codified at Section 1798.82 (and 1798.29 for government entities) was modified by SB 24 primarily to specify the contents of the mandatory notice.

New Employee Rights Posting Requirement; Banks Covered Under Prior Rule

August 30, 2011

Last June the U.S. Department of Labor issued a rule implementing Executive Order 13496. The Executive Order requires certain federal departments and agencies to include in their government contracts provisions requiring contractors and subcontractors with whom they do business to post notices informing their employees of their federal labor rights.

Regulations Z and M Exemptions Adjusted to $51,800

August 30, 2011

The Dodd-Frank Act raised the threshold for consumer credit transactions that are exempt from the Truth in Lending Act and Consumer Leasing Act from $25,000 to $50,000. Earlier this year the Federal Reserve Board issued rules implementing these changes (the “April 4 Rules”).

New Regulation CC Dollar Threshold Effective July 21, 2011

July 20, 2011

Section 1086 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) amends the Expedited Funds Availability Act (the “EFA,” implemented by the Federal Reserve Board’s Regulation CC at 12 CFR Part 229) by increasing the amount of deposited funds that banks must make available for withdrawal by the next business day from $100 to $200.

Final Rules Implement Lifting of Ban on Interest on Demand Accounts

July 19, 2011

Section 627 of the Dodd Frank Act repealed the statutory prohibition against the payment of interest on demand deposits. The Federal Reserve Board and the FDIC separately issued final rules to implement the lifting of the ban.

New California Bill Fixes 2010 Law On Short Sales

July 18, 2011

This Bulletin was prepared for CBA by Peter Munoz [1], partner with Reed Smith and member of the CBA Legal Affairs Committee.

Regulation Z Exemption Threshold Raised to $50,000

July 11, 2011

Pursuant to the Section 1100E of the Dodd-Frank Act, the Truth in Lending Act (TILA) was amended to increase the threshold for transactions that are exempt from Regulation Z from $25,000 to $50,000. The Federal Reserve Board issued a final regulation (“Final Rule”) to implement this change, which will become effective on July 21, 2011.

U.S. Supreme Court Strikes Down California Ban on Arbitration Class Action Waivers

May 2, 2011

The United States Supreme Court overturned a decision arising in California that had invalidated contractual restrictions against class-wide arbitration. CBA has closely followed this case and filed briefs in the Ninth Circuit where it was originally litigated and in the U.S. Supreme Court. The decision of AT&T Mobility v.

Regulation Z Exemption Adjusted Pursuant to Dodd-Frank Act

March 29, 2011

Pursuant to the Dodd-Frank Act, the Federal Reserve Board issued a final regulation increasing the threshold for consumer credit transactions that are exempt from the Truth in Lending Act from $25,000 to $50,000. The $25,000 threshold amount had been in place since the 1980s.

Regulation M Exemption Adjusted Pursuant to Dodd-Frank Act

March 29, 2011

Pursuant to the Dodd-Frank Act, the Federal Reserve Board issued a final rule increasing the threshold amount for consumer lease transactions that are exempt from the Consumer Leasing Act (CLA) from $25,000 to $50,000 [1]. A consumer lease is exempt if the total contractual obligation exceeds the threshold amount in effect at the time of consummation.