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#1282054 - 11/05/09 09:13 PM
Re: Regulation Z - Open End changes - 7-1-10
DD Regs
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Joined: Mar 2009
Posts: 124
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I'm having a hard time with that too - the edocket for the proprosed Feb 22 effective date also contains July 2010 items. How do you determine which part is applicable for Feb and which is for July?
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#1282097 - 11/05/09 09:53 PM
Re: Regulation Z - Open End changes - 7-1-10
tyond
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Joined: Aug 2002
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This is how I understand it. Most of the remaining Cr Card Act provisions are effective 2-22-2010 with 2 that will be effective by May 2010. (reasonableness of penalty fees and int rate reductions) UDAP and Reg Z changes published in FR in Jan 09 are effective 7-1-2010. (Parts unaffected by the Cr Card Act - the rest will probably be amended or withdrawn)
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#1282143 - 11/05/09 10:29 PM
Re: Regulation Z - Open End changes - 7-1-10
ahou
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Cheeseheadland
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<--- so thrilled we do not maintain our own credit card portfolio... heck we are still trying to comply witht he HELOC statement billing changes!
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#1282235 - 11/06/09 01:02 PM
Re: Regulation Z - Open End changes - 7-1-10
#Just Jay
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Somewhere in the middle
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Do you do anything with gift cards?
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#1282286 - 11/06/09 02:05 PM
Re: Regulation Z - Open End changes - 7-1-10
DD Regs
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Joined: Oct 2006
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Cheeseheadland
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No, they were such a money loser we dumped them a year or so ago.
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#1282414 - 11/06/09 03:35 PM
Re: Regulation Z - Open End changes - 7-1-10
#Just Jay
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Joined: May 2002
Posts: 6,259
NW IL
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<--- so thrilled we do not maintain our own credit card portfolio... heck we are still trying to comply witht he HELOC statement billing changes! Bah! Humbug.
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#1282991 - 11/06/09 09:26 PM
Re: Regulation Z - Open End changes - 7-1-10
QCL
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Joined: Mar 2009
Posts: 124
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we handle our credit card portfolio and while our processor is handling some system capabilities, we are still drowning with those items that are considered client driven or specifically on us (ex. toll free number for CCC info/ability to repay/posting of agreement)
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#1283233 - 11/09/09 02:27 PM
Re: Regulation Z - Open End changes - 7-1-10
tyond
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Joined: Jan 2008
Posts: 6,389
Looking for My Happy Place....
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So, does this new amendment to the CCARD Act mean that all of the work we did on our OD lines and HELOCS to get the billing right - was a waste of time and effort?
Last edited by Tigg; 11/09/09 02:29 PM. Reason: Can't write on a Monday!
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#1283238 - 11/09/09 02:30 PM
Re: Regulation Z - Open End changes - 7-1-10
Tigg
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Cheeseheadland
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I am so thoroughly confused.
More so than usual.
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#1283248 - 11/09/09 02:46 PM
Re: Regulation Z - Open End changes - 7-1-10
#Just Jay
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Power Poster
Joined: May 2002
Posts: 6,259
NW IL
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Me too. http://www.bankersonline.com/topstory/topstory.htmlPresident Signs Credit CARD Act Amendment On Friday, President Obama signed the Credit CARD Technical Corrections Act of 2009. The amendment adds language to section 163(a) of the Truth in Lending Act to restrict the new requirement for billing at least 21 days before the payment due date on open end credit plans to credit card accounts. The change will require the Federal Reserve Board to issue a conforming amendment to Regulation Z section 226.5(b)(2), where the 21-day billing rule was implemented as of August 22, 2009. Signings; Act 11/09/09
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#1283300 - 11/09/09 03:18 PM
Re: Regulation Z - Open End changes - 7-1-10
Tigg
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Joined: Feb 2003
Posts: 962
PA
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So, does this new amendment to the CCARD Act mean that all of the work we did on our OD lines and HELOCS to get the billing right - was a waste of time and effort? That sounds exactly right - we wasted time, effort, and money to change system billing parameters, notify customers, etc. - only to be told later that it wasn't required for non-credit card related open-end credit. Makes me not want to be proactive. Why should I try to be compliant as of the effective date of these new regs when 2-3 months later there is an amendment to say "Oh wait...we didn't mean that." Disheartening to say the least 
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#1283317 - 11/09/09 03:28 PM
Re: Regulation Z - Open End changes - 7-1-10
AuditorK
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Cheeseheadland
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<--- possibly thrilled that we are still out of compliance!!
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#1283399 - 11/09/09 04:50 PM
Re: Regulation Z - Open End changes - 7-1-10
Tigg
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Cheeseheadland
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I'm serious! I wish we could confirm this means what we think it means.
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#1283499 - 11/09/09 06:13 PM
Re: Regulation Z - Open End changes - 7-1-10
#Just Jay
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Well, I definitely hope it's to all of our benefit - especially those who are still having problems with something we only had a grand total of maybe 60 days to implement.
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What would you do if you knew you could not fail? ~ Dr. R Schuller
My opinion only.
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#1283500 - 11/09/09 06:14 PM
Re: Regulation Z - Open End changes - 7-1-10
Tigg
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Posts: 14,390
Cheeseheadland
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I emailed our state's banking association this morning... they have been petitioning hard to have it reworked... waiting to see what their responce is.
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#1283544 - 11/09/09 06:46 PM
Re: Regulation Z - Open End changes - 7-1-10
QCL
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Looking for My Happy Place....
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Better to be examined now while everything is still new QCdL. Oh, and ask lots of questions! (and share the answers, please.  )
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What would you do if you knew you could not fail? ~ Dr. R Schuller
My opinion only.
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#1284841 - 11/10/09 08:54 PM
Re: Regulation Z - Open End changes - 7-1-10
Tigg
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Joined: Mar 2009
Posts: 124
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Does anyone know if the tabular requirements in 226.5(a.3) are subject to Feb implementation or July? I thought they were July requirements (except for the repayment table format on the statements).
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#1284995 - 11/10/09 10:24 PM
Re: Regulation Z - Open End changes - 7-1-10
QCL
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Power Poster
Joined: Mar 2004
Posts: 2,507
Up North
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Me too. http://www.bankersonline.com/topstory/topstory.htmlPresident Signs Credit CARD Act Amendment On Friday, President Obama signed the Credit CARD Technical Corrections Act of 2009. The amendment adds language to section 163(a) of the Truth in Lending Act to restrict the new requirement for billing at least 21 days before the payment due date on open end credit plans to credit card accounts. The change will require the Federal Reserve Board to issue a conforming amendment to Regulation Z section 226.5(b)(2), where the 21-day billing rule was implemented as of August 22, 2009. Signings; Act 11/09/09 This is enough to make a person go postal!
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#1284998 - 11/10/09 10:31 PM
Re: Regulation Z - Open End changes - 7-1-10
tyond
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Joined: Aug 2002
Posts: 3,094
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Tabular format requirements are part of the July 2010 requirements.
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#1285313 - 11/12/09 03:40 PM
Re: Regulation Z - Open End changes - 7-1-10
ahou
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100 Club
Joined: Mar 2009
Posts: 124
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Great, I thought they were for July. With the Feb requirements mixed in with the July stuff on the edocket it is becoming difficult to develop an impact document with effective dates.
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#1285523 - 11/12/09 07:09 PM
Re: Regulation Z - Open End changes - 7-1-10
Tigg
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Joined: Apr 2002
Posts: 213
KS
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Amendment issued -> Short implementation time -> Scramble to comply -> Finish on time -> Amendment issued to fix "oops"
No wonder I'm bald. I hope this isn't a sign of things to come with this flurry of new stuff to deal with.
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#1285676 - 11/12/09 09:26 PM
Re: Regulation Z - Open End changes - 7-1-10
Brad B
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So, the million dollar question, if this means what we think it means, is are you going to change everything back? I am thinking no, but curious what eveyone else is thinking.
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#1285681 - 11/12/09 09:28 PM
Re: Regulation Z - Open End changes - 7-1-10
Tesla
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Posts: 14,390
Cheeseheadland
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My guess is, lets not hold our breath.
My money says that the revised HELOC final rules next year will have some sort of billing change built into it. I can't see this going away.
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@ JJ!
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