Today is supposedly the day….
I am expecting a request for an extension before submitting the new regulations and guidelines…
Important Note: UIGEA required that new guidelines and regulations be created and issued with 270. NOT that they be implemented by financial institutions. I guarantee you that after guidelines are issued there will be a similar grace period to allow the banks to adopt the new policies and come into compliance. So even IF guidelines do come out today it will be quite some time before they can be put into play.