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Who's on First?

Oct 31, 2017
Financial Institutions

In the 1930s and 40s, Abbott and Costello, a comedian duo, entertained audiences with their famous sketch “Who’s on First?” The sketch used plays on words and names. The first base player was named “Who,” the second base player was “What,” and third base was “I Don’t know.” Costello was trying to learn the names of the team members, and as Abbott tried to provide them, Costello became confused and annoyed resulting from the miscommunication of the meaning of the words.

In compliance, the meaning of a word or words is very important because the definition will impact how you interpret a law or regulation. The meaning of the exact word or words varies from regulation to regulation, so it is always important to refer to the “Definitions” section when researching a question, implementing a policy or procedure, or introducing a new service.

Just one example of this is the term “business day.” Here are a few definitions:

  • Regulation CC’s definition is, “A calendar day other than a Saturday or a Sunday, January 1, the third Monday in January, and February, the last Monday in May, July 4, the first Monday in September, the second Monday in October, November 11, the fourth Thursday in November, or December 25. If January 1, July 4, November 11, or December 25 fall on a Sunday, the next Monday is not a business day.”
  • Regulation E defines it as, “Any day on which the offices of the consumer's financial institution are open to the public for carrying on substantially all business functions.”
  • Regulation DD states a business day “means a calendar day other than a Saturday, a Sunday, or any of the legal public holidays specified in 5 U.S.C. 6103(a).”
  • Regulation Z has two definitions:
    • A day on which the creditor's offices are open to the public for carrying on substantially all of its business functions.

However, for purposes of rescission under §§1026.15 and 1026.23, and for purposes of §§1026.19(a)(1)(ii), et. al,, the term means all calendar days except Sundays and the legal public holidays Feeling like Costello? Confused and annoyed by the way a regulation is written and the difficulty of understanding what is required? We can help with our subscription service designed to assist your financial institution’s compliance staff. Simply email a question to us and receive a response back within one business day from our Wipfli regulatory compliance experts. Click on the link for details:

If you want to bring some humor into your day, watch the “Who’s on First?” sketch on YouTube.  

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