In FIL 54-2004 the FDIC indicates its supervised institutions need to begin preparation for Check 21 whether or not they decide to truncate or exchange electronic check images. Issues such as training, disclosures and risk analysis figure prominently in the announcement.

Based on past practices in connection with impending regulations, FDIC supervised banks expecting on-site examinations prior to the end of October should expect to be asked about their preparation to date.

Has there been any recent "word on the street" of when we might expect the final rules?

The following are my notes from last week's BAI Transpay Conference:
Regulation CC

§ Many comments received and are being reviewed
§ Still anticipating a late June/early July release of regulation changes with “safe-harbor” language

Regulation J

§ Comments for response to be published in May, 2004
§ Final rule changes in late summer

Operating Circular #3

§ This circular is the agreement by which a bank enters into forward image collection arrangement or receives image presentment cash letters
§ Changes will be published after Regulation changes are identified
§ Appears to be significant changes in OC #3

The FRB is mandated to publish the "safe-harbor" language no later than 90 days prior to implementation (July 28). This dealine does not apply to the regulation itself, but they are doing everything to be earlier than that date.