After the public comment period, the rules will be adjusted and finalized. One those final rules are published, the agencies and banking systems involved will them be given an additional period of time --- mentioned as six months in the notice --- before banks and such will be asked to be compliant. Allowing for the comment period, the expected revisions and republication of the rules and the six months (or more) for putting any system into place, this suggests that it will be at least late 2008 before any UIGEA-authored system would be in place. That leaves some time for legal challenges.
As for comments, those who do so are generally encouraged to point out fatal flaws in the administration of the UIGEA, such as the trampling of First Amendment rights, the unfunded mandate assigned to the banking industry and massive misstatement of manpower needed to properly administer the effort, and what amounts to a deputizing of that same banking industry to apply and enforce regulations that they have no right to monitor. Leastways, if I were going to write a comment, that’s where I’d start.
As for where to send comments, the notice offers several choices. To send to the Governors of the Federal Reserve Board, this is what to do:
Use docket number R-1298 to tag your comment to the proper set of rules, no matter what. Then choose any of these online options:
Jennifer J. Johnson
Secretary, Board of Governors for the Federal Reserve System
20th Street and Constitutional Avenue, N.W.
Washington, D.C. 20551
Remember, public comments are indeed public, and can be viewed by others.
One can also submit comments to the Treasury. Here’s that process:
Department of the Treasury
Office of Critical Infrastructure Protection and Compliance Policy
Room 1327, Main Treasury Building
1500 Pennsylvania Ave., N.W.
Washington, D.C. 20220
Very important: Commentors are required to submit their comments to both agencies. Now go get ‘em.