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#1282374 - 11/06/09 03:19 PM Reg Z - credit card payments - 2/2010
CalifDreamin Offline
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CalifDreamin
Joined: Mar 2002
Posts: 2,264
Far from Calif
In the Reg. Z proposal implementing the Credit CARD Act changes that will be effective 2/2010...regarding payments, the commentary for 226.10(a)-2(iv) states
Quote:

"Payment made via the creditor's Web site is received on the date which the consumer authorizes the creditor to effect the payment, even if the consumer gives the instruction authorizing that payment in advance of the date on which the creditor is authorized to effect the payment. If the consumer authorizes the creditor to effect the payment immediately, but the consumer's instruction is received after 5 p.m. or any later cut-off time specified by the creditor, the date on which the consumer authorizes the creditor to effect the payment is deemed to be the next business day....Payment via creditor's Website. If a creditor promotes electronic payment via its Web site (such as by disclosing on the Web site itself that payments may be made via the Web site), any payments made via the creditor's Web site would generally be conforming payments for the purposes stated above."


What does this mean exactly? If they pay their credit card via the website, the effective date must be that day if done before 5? I was told by our credit card dept. it can take up to 48 hrs (not just posting but they effective/post at the same time right now for this which can be up to 48 hrs from when the customer makes that online payment).
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Lending Compliance
#1283289 - 11/09/09 03:09 PM Re: Reg Z - credit card payments - 2/2010 CalifDreamin
Phoenix Offline
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Phoenix
Joined: May 2003
Posts: 832
southeast
I think you're right : (

Here's how I think existing TILA changed (see CAPS):

"Payments received from an obligor under an open end consumer credit plan by the creditor shall be posted promptly to the obligor’s account as specified in regulations of the Board. Such regulations shall prevent a finance charge from being imposed on any obligor if the creditor has received the obligor’s payment in readily identifiable form BY 5:00PM ON THE DATE ON WHICH SUCH PAYMENT IS DUE in the amount, manner AND LOCATION indicated by the creditor to avoid the imposition thereof."

There's the tiniest bit of wiggle room if the electronic payment is actually processed by a third party provider, or received on a non-business day; however, this clause will make all of us re-think our definitions of what we have as "conforming payments" in our contracts. Sounds like something worth commenting on - even electronic payments need to go through NACHA rules and safeguards....
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