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#1240385 - 08/27/09 05:30 PM Regulation Z - Open End changes - 7-1-10
RR Joker Offline
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#1242755 - 09/01/09 03:48 PM Re: Regulation Z - Open End changes - 7-1-10 RR Joker
tyond Offline
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Posts: 124
Is there going to be a thread on card act changes for Feb. 2010? Some of the Reg Z and Reg AA will get pulled into that implementation date.

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#1245179 - 09/03/09 10:36 PM Re: Regulation Z - Open End changes - 7-1-10 tyond
Ann Offline
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Posts: 556
South Carolina
I'm tagging onto this thread because of the effective date of 7/1/2010. However, I am learning and reading today that section 226.9(g)of the Interim Final Rule went into effect August 20, 2009 along with other provisions at that time.

"If a consumer engages in behavior that triggers penalty pricing on August 20, 2009, the creditor must comply with new Section 226.9(g) and, accordingly, must provide the consumer with a notice at least 45 days in advance of the effective date of the increase."(page 59)

BOL still lists the implementation date for this section as 7/1/2010. I have been so busy implementing the 21-day rule for open-end credit that this passage totally missed my radar. If it was buried in previous lengthy threads over that subject, then I missed it there too and I apologize for the question.

Is there any hope that I have misunderstood this shocking revelation????

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#1245194 - 09/04/09 12:27 AM Re: Regulation Z - Open End changes - 7-1-10 Ann
rlcarey Offline
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"BOL still lists the implementation date for this section as 7/1/2010. "

It is in the current 226.9 section on BOL? You might want to check again. It was effective 8/20/09.
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#1245209 - 09/04/09 02:35 AM Re: Regulation Z - Open End changes - 7-1-10 rlcarey
Ann Offline
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You are correct - my mistake - thanks!

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#1258262 - 09/29/09 11:22 AM Re: Regulation Z - Open End changes - 7-1-10 Ann
Tigg Offline
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Looking for My Happy Place....
Is anyone else concerned that there is a bill being presented to congress right now to move up to December 1 the February requirements? That would put them BEFORE the RESPA changes.....

I think I feel sick
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#1258399 - 09/29/09 02:06 PM Re: Regulation Z - Open End changes - 7-1-10 Tigg
Phoenix Offline
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southeast
Write your congressman (or woman)!
http://www.house.gov/apps/list/press/financialsvcs_dem/21malone_011_xml.pdf

It's HR 3639.

ALL remaining parts of the CARD Act would become due 12/1/09, including
- the look-back for all rate increases
- the requirement that all penalty fees be “reasonable and proportional”
- the gift card rules

Our best bet is to contact our Senators and Representatives as individual voters and say this just won’t work – it’s not a matter of desire. Banks know they need to meet consumers’ needs AND make sufficient $ to meet their safety and soundness requirements. Pushing up compliance deadlines will stress systems and processes beyond the breaking point, and force banks to reconsider whether they can serve retail customers at all, let alone in the manner these legislators desire.

We can’t wait for banking lobbying groups to act, and they are acting as best as they can. The reason Frank is already modifying the CPFA proposal is because of thousands of individual emails and phone calls and newspaper editorials that appeared, not contacts by a couple of dozen lobbying groups. We need to do the same here. Individuals vote; lobbying groups don’t.
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#1258495 - 09/29/09 03:57 PM Re: Regulation Z - Open End changes - 7-1-10 Phoenix
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It's HERE, round 2 of proposed interpretations, 841 pages: http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20090929a1.pdf

Comments DUE in 30 DAYS (10/29/09) - Happy Halloween!
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#1258602 - 09/29/09 05:25 PM Re: Regulation Z - Open End changes - 7-1-10 Phoenix
Tigg Offline
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Looking for My Happy Place....
sick
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#1265560 - 10/13/09 04:24 PM Re: Regulation Z - Open End changes - 7-1-10 Tigg
tyond Offline
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Is anyone out there looking at doing a promotional convenience check mailing for the Christmas holidays? Would the disclosures for those checks need to be in the new table format required since the promotional rate would extend into the effective date of the Card Act (and possibily Reg Z)?

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#1266426 - 10/14/09 05:59 PM Re: Regulation Z - Open End changes - 7-1-10 Phoenix
Wyogirl Offline
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Laramie, WY. USA
My phone is ringing off the hook from customers who do not want their DDL payment to change. (It is currently the statement cut day and is automatically deducted from their account on this day.) How are you all handling this? Can we put their payment day back on the statement cut day if that is their wish? I'd rather make my customers happy than abide by a law that was not clearly thought out and ill advised. What is my penalty for not complying? (My HELOCs are in compliance, no big deal for those.)

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#1266514 - 10/14/09 06:56 PM Re: Regulation Z - Open End changes - 7-1-10 Wyogirl
CSB98 Offline
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For those that wanted a specific payment date, we left them as is. I would just make a note in the file for these customers that they were informed of the change but opted to have the payment made sooner.

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#1266816 - 10/14/09 10:53 PM Re: Regulation Z - Open End changes - 7-1-10 CSB98
Wyogirl Offline
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I thought that would be my course of action, but was looking for back up here. I finally called my lead examiner, (just got off the phone) and she told me under no uncertain circumstances would customers be "allowed" to keep their payment date. They have no choice but to accept this. It's finally happened...I live in a country where the government thinks it can make better decisions for me than I can.

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#1270372 - 10/21/09 01:17 PM Re: Regulation Z - Open End changes - 7-1-10 Wyogirl
rockchalk02 Offline
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Federal Reserve published proposed rule today in Federal Register regarding open-end credit.

http://edocket.access.gpo.gov/2009/pdf/E9-23733.pdf

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#1270880 - 10/21/09 07:21 PM Re: Regulation Z - Open End changes - 7-1-10 rockchalk02
QCL Offline
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NW IL
Does this now mean that comments are due 11/21 rather than 10/29?

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#1270899 - 10/21/09 07:34 PM Re: Regulation Z - Open End changes - 7-1-10 QCL
rockchalk02 Offline
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The proposed rule out today has a comment period that ends 11/20/09. The new rule also contains the other 3 rules that the Board has issued this year--however, I have not read anything that would change comment periods within these other rules. Its 210 pages--I am still reading frown

"The Board is aware that the existence of multiple concurrent Regulation Z rulemakings pertaining to open-end credit has the potential to cause confusion." 74 FR 54125

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#1270984 - 10/21/09 08:08 PM Re: Regulation Z - Open End changes - 7-1-10 Wyogirl
QCL Offline
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Originally Posted By: wyogirl
...I finally called my lead examiner, (just got off the phone) and she told me under no uncertain circumstances would customers be "allowed" to keep their payment date. They have no choice but to accept this...


Whaaat?!?

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#1270994 - 10/21/09 08:14 PM Re: Regulation Z - Open End changes - 7-1-10 QCL
ahou Offline
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ahou
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I'm reading the proposal that was in my mail box today and it says the bank may adjust the due date from time to time, for example when the customer requests a new due date; however, the new date must be the same numerical date each month on an ongoing basis.
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#1271925 - 10/22/09 06:57 PM Re: Regulation Z - Open End changes - 7-1-10 ahou
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HR 3639 to move up implementation of CARD Act to 12/1/2009 passed House Financial Services Committee just now on voice vote. Bernanke's letter was read into the Committee debate without effect. HR 3639 now goes onto the entire House of Representatives.
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#1272702 - 10/23/09 04:24 PM Re: Regulation Z - Open End changes - 7-1-10 Phoenix
tyond Offline
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I think I'm going to be sick on 226.58, the requirements to make card agreements available on our publicly available website with an addendum of 'pricing information' - not to mention allowing a customer to request via website or phone the same information for products that we no longer offer but still have open accounts for.

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#1272780 - 10/23/09 05:11 PM Re: Regulation Z - Open End changes - 7-1-10 Phoenix
RR Joker Offline
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Originally Posted By: Phoenix
HR 3639 to move up implementation of CARD Act to 12/1/2009 passed House Financial Services Committee just now on voice vote. Bernanke's letter was read into the Committee debate without effect. HR 3639 now goes onto the entire House of Representatives.


Maybe this will help you?

Credit Card Bill Includes ICBA-Advocated Exemption for Small Issuers
Following vigorous ICBA congressional outreach, the House Financial Services Committee approved an amendment that would exempt small issuers from legislation speeding up effective dates of new credit card regulations, representing a significant concession for community banks.
The ICBA-advocated amendment to the Expedited CARD Reform for Consumers Act (H.R. 3639), which was approved by the committee, would exempt credit card issuers with fewer than 2 million credit cards in circulation from having to meet the Dec. 1, 2009, effective date included in the legislation. Instead, community bank issuers would face the Feb. 22, 2010, and Aug. 22, 2010, effective dates already required by the Credit CARD Act.
The amendment, sponsored by Reps. Brad Sherman (D-Calif.) and Shelly Moore Capito (R-W.Va.), recognizes that community banks do not engage in the misleading practices targeted by these bills. Federal Reserve Chairman Ben Bernanke said this week that moving up the effective date would result in unintended consequences, particularly for smaller issuers.
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#1280897 - 11/04/09 08:53 PM Re: Regulation Z - Open End changes - 7-1-10 RR Joker
#Just Jay Offline
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The speedup date just passed the house.

http://news.moneycentral.msn.com/provide...amp;id=10634506
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#1281258 - 11/05/09 01:38 PM Re: Regulation Z - Open End changes - 7-1-10 #Just Jay
zosogirlie Offline
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As an issuer of less than 2 million cards in our portfolio, how does the Credit Card Act of 2009 affect us in relation to this expedited enactment? We are in the process of notifying our customers in November of a rate increase effective in January.

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#1281412 - 11/05/09 03:03 PM Re: Regulation Z - Open End changes - 7-1-10 zosogirlie
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NW IL
Good question.

Stop buying [censored].com has a good breakdown - http://www.stopbuyingcrap.com/personal-finance/credit-card-act-2009/

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#1281585 - 11/05/09 04:51 PM Re: Regulation Z - Open End changes - 7-1-10 QCL
DD Regs Offline
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Somewhere in the middle
SO do all the changes take effect now?
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