This entry is brought to you by guest blogger and Calyx compliance & product manager, Roy Mitchell.
In August 2010 the FED issued an interim rule that changed the way interest rate and payment information was disclosed in the TIL. This August interim rule became mandatory in January 2011.
After the interim rule was released, the industry found that there was a lot of ambiguity in the rule definition which caused issues in interpreting the initial interim rule. Therefore, in December 2010 the FED issued a second interim rule to clarify the ambiguities; this rule became mandatory in October 2011.
Due to the timing of the release of the interim rules and our implementation process, Calyx chose to implement the requirements of both the August interim rule (mandatory Jan 2011) and the December interim rule (mandatory in Oct 2011) in our Point 7.4 release. Therefore, there are no additional updates required in Point to comply with the rules that became mandatory as of Oct 2011.