You are all likely aware that the Section 1071 Rule is in a state of flux. There have been lawsuits, court cases, stays of rulings and that was all going on even before we got a new Administration with differing views. It really is chaotic right now and it’s hard to know what to do, what not to do, etc. We get the impression that a lot of financial institutions think 1071 is just going to go away and while that is a possibility, we think its very, very small. The much more likely outcome is that 1071 will be rewritten and likely look different than what was expected.
Jerod explains more in the video.