Monday, August 22, 2011

How to Read a Regulation


1. First ask your spouse, co-worker, or friend to feel your forehead to see if you are feverish. Often the onset of a catastrophic illness will affect the mind to the point where reading regulatory gibberish becomes a strong desire if not an addiction.
2. Next, acquire a bottle of liquor and take several large drinks.
3. Finally, sit in a straight, comfortable chair in a clean, ventilated, well-lighted place with plenty of freshly sharpened #2 pencils. (Wait a minute, that’s from my college term paper days…never mind)
4. Now, finally, open up the “BOOK OF RULES”.
5. You can find a summary of the regulation near the beginning of the Federal Register’s rendition of the new regulation. You should read this as it’s akin to looking over a course map of a new golf course before you play. You want to get a lay of the land.
6. Understand that you and I think differently than the folks who wrote the “BOOK OF RULES”, so it’s important to understand their language. We, unlike most of them, have actually been in a bank at one time, understand the difference between a debit and a credit, and have seen an actual customer in their native habitat. One of the best ways to understand the language is by reading the definitions contained in the regulation. Most regulations have lots of definitions, and one would think that all the regulations would agree on what the terms “business day” or “dwelling” mean. WRONG! Just like two opposing football teams having guys with the #12 on their jersey, and those two guys with the same number are different people, the same word or phrase in one regulation may mean something different in the regulation you are reading. Don’t presume that you understand what the rule-writer is saying until you learn the language. After reading the regulation’s definitions, you just might find that the regulation doesn’t even apply to your situation.
7. Take a couple more large swigs from your bottle. Tell yourself that you can do this.
8. Curse yourself for not taking that opportunity to go to law school.
9. Read, think, read, think, read, think. Take another swig. Let your eyes glaze over after reading several thirteen line sentences complete with commas, semi-colons, parentheses, double parentheses, brackets, reference citations to multitudes of other places in the regulation, and italicized words.
10. It is now 1:30 a.m. as you curse the government out loud and wake up your spouse, child, or pet.
11. Make a note to call American Bank Systems tomorrow morning and let their team of experts, as Kris Kristofferson so aptly penned it, "Help You Make It Through the Night".

At American Bank Systems and ABS Consulting, we have the tools and expertise to bring sense out of nonsense. We’ll save you time, money, and wear and tear on your liver.

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