It will have some effect for depositories, especially depositories who do a lot of business stemming from brokers.

One paradoxical effect it will have is that some conservative depositories will use these guidances, and especially the suggested disclosure formats, as a roadmap to start offering these loans when they hadn’t before. Conforming to the suggested disclosure guidelines offers institutions a way to cut potential legal risks. They won’t do tons of them, but they will start offering them.

According to the primary guidance, state regulators of non-depository lenders had agreed to institute similar regulations for non-depository lenders. But they haven’t yet, and there was nothing holding them back, so I’m not holding my breath.