Final LOan Regs- Effective date???

[Guest AFRICA6796]

The Final LOan Regs gives dates as :

Effective Date: These regulations are effective December 3, 2002.

Applicability Date: These regulations apply to assignments, pledges, and loans

made on or after January 1, 2004.

What exactly does this mean? How is effective date differ from applicability date?

[MGB]

Just to confuse the issue a little more: In the proposed regulations, it stated that the final regulations would not be effective until the calendar year that starts at least 6 months after final regulations are issued. I guess they are ignoring that prior statement.

[MGB]

I just spoke with Vernon Carter, author of the regulations. He says that they are effective immediately, but you can optionally ignore them until 1/1/2004, at which time you must follow them.

[Guest hpaine]

Technically, we can avoid using the new regs until 1/1/04?

[E as in ERISA]

And even then, we only use them on loans that are created on or after that date.