by Amy Kleinschmit, Director of Compliance

The Federal Reserve Board has announced that it is delaying the implementation of the second phase of its program to simply the administration of reserve requirements. Originally, these amendments would have gone into effect on January 24, 2013. The new effective date is now set for June 27, 2012.

As you may recall, the Federal Reserve Board published its final rule that amended Regulation D earlier this year on April 12, 2012. This final rule included:

1.      Creating a common two-week maintenance period for all depository institutions;

2.      Creating a penalty-free band around reserve balance requirements in place of using carryover and routine penalty waivers;

3.      Discontinuing as-of adjustments related to deposit report revisions and replace all other as-of adjustments with direct compensation (amendment effective July 12, 2012); and

4.      Eliminating the contractual clearing balance program (amendment effective July 12, 2012).

The second phase of the final rule includes the provisions relating to the common two-week maintenance period, the penalty-free band, and the elimination of carryover and routine penalty waivers. The Board is delaying until June 27, 2013, the January 24, 2013, date to allow the Federal Reserve to further develop and test the automated systems necessary to support the second phase of this final rule.

The Federal Reserve Board’s announcement can be found here: http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20121026a1.pdf

Should you have any questions or concerns on this or any other compliance or regulatory issue, please do not hesitate to contact Amy Kleinschmit at akleinschmit@cuad.coop or 701.214.9721.