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?

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.

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.

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

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