Thread Options
|
#1286552 - 11/13/09 09:50 PM
Re: Regulation Z - Open End changes - 7-1-10
#Just Jay
|
100 Club
Joined: Apr 2002
Posts: 213
KS
|
We're going to leave it be. The work is already done.
_________________________
"Sarchasm" is the gulf between the author of sarcastic wit and the person who doesn't get it
|
Return to Top
|
|
|
|
#1286860 - 11/16/09 02:40 PM
Re: Regulation Z - Open End changes - 7-1-10
QCL
|
100 Club
Joined: Mar 2009
Posts: 124
|
Here goes - this is what I came up with for Feb 22 requirements on credit cards (not including the 8/20 changes). I welcome any additions/corrections. Does anyone know if the ability for cardholders to reject requested balance transfers after they rec. disclosures (10 days after mailing) is for Feb or July? Thanks!!
Same Pmt Due Date (7.b) Min Pmt Warning (7.b) Late Pmt Warning (7.b) Repayment Estimate (7.b) Credit Counseling Info (7.b) New Disclosures at Renewal if any changes were not previously provided (9.e) Protected Balances due to CIT or Penalty Notices (55) Reasonable Cut Off Time (10.b) Ability to Repay (51) Under 21 Account Opening and Line Increases (51.b) Overlimit Fee Requirements (56) Terms Provided to Board (58.d) (registerd by Feb 1) Terms Provided Online (58.f) Payment Allocation (53) Fees for Making Payment (10.e) Estate Debt Settlement (11.c) 6 Month Requirement for Temp Rates (55.b) Double Cycle Billing (54) Partial Grace (54) Fixed Terminology (16.f) 25% Fee Limit for 1st year (52) Removal of Penalty after 6 months of pmt (55) New Account New Disclosures (5.b)
|
Return to Top
|
|
|
|
#1288765 - 11/18/09 03:47 PM
Re: Regulation Z - Open End changes - 7-1-10
Ninky
|
Platinum Poster
Joined: May 2003
Posts: 832
southeast
|
check out Federal Register p. 54126, middle and right column.
_________________________
From the end spring new beginnings. Pliny the Elder
|
Return to Top
|
|
|
|
#1289713 - 11/19/09 05:23 PM
Re: Regulation Z - Open End changes - 7-1-10
Ninky
|
Power Poster
Joined: Aug 2002
Posts: 3,094
|
This is the way I understand it (could be wrong - it is so confusing):
The Credit Card Act applies the safe harbor 5 p.m. cut-off rule to all open-end credit plans and to all forms of pmt, including open-end (homesecured) credit. Proposed § 226.10(b)(2)(ii) (payments made in person) would also apply to all open-end credit. This is consistent with current § 226.10, which applies to all open-end credit.
_________________________
Opinions are my own and not of my employer.
|
Return to Top
|
|
|
|
#1290016 - 11/19/09 09:35 PM
Re: Regulation Z - Open End changes - 7-1-10
Ninky
|
Power Poster
Joined: Aug 2002
Posts: 3,094
|
Yes.
_________________________
Opinions are my own and not of my employer.
|
Return to Top
|
|
|
|
#1290107 - 11/19/09 10:23 PM
Re: Regulation Z - Open End changes - 7-1-10
ahou
|
Power Poster
Joined: Aug 2002
Posts: 3,094
|
The final rule makes most of the provisions effective 30 days after publication. This approach allows institutions to receive, with only a minimal delay, a safe harbor for using the model privacy form but allows you to continue to use the alternative language (the old sample clauses) until the end of 2010.
Jan 1, 2012, model disclosures we use now will be removed and paragraph (g) which states the following will be removed (because it will no longer apply):
(g) Sample clauses. Sample clauses illustrating some of the notice content required by this section are included in Appendix B of this part. Use of a sample clause in a privacy notice provided on or before December 31, 2010, to the extent applicable, constitutes compliance with this part.
_________________________
Opinions are my own and not of my employer.
|
Return to Top
|
|
|
|
#1291367 - 11/23/09 03:38 PM
Re: Regulation Z - Open End changes - 7-1-10
ahou
|
100 Club
Joined: Mar 2009
Posts: 124
|
I get that 226.10 is for all open end credit, but sec. 226.10(b.3) would be for credit card payments only. In person payments on a credit card account would need to be accepted until close of business, but other open end payments would be until 5:00. So if a bank teller is open until 9:00 pm, then they have to accept payment until 9:00 on the payment due date?? We give a buffer from the due date and the time f/c and late fees assess. If we take a payment at 9:00 on a Sat., it would not process until Monday and due to the buffer no charges would appear on the acct. I assume the transaction date would have to read as the date for Saturday and not Monday.
|
Return to Top
|
|
|
|
#1296896 - 12/02/09 03:17 PM
Re: Regulation Z - Open End changes - 7-1-10
tyond
|
Platinum Poster
Joined: May 2003
Posts: 832
southeast
|
At a branch - yup. Payment needs to be effective-dated the same day as it is received. Only possible wiggle room is if, after 5pm, no one at the branch can open any deposit account or fund a loan/line - see the 226.2 definition and OSC for business day.
_________________________
From the end spring new beginnings. Pliny the Elder
|
Return to Top
|
|
|
|
#1310273 - 12/21/09 05:35 PM
Re: Regulation Z - Open End changes - 7-1-10
CRCM2010
|
Gold Star
Joined: Mar 2008
Posts: 294
The Texas Hill Country
|
We too offer lines of credit but no credit cards. The way I see it, the following section revisions will apply for us:
226.5(a)(2)(iii)- initial disclosures and use of "penalty apr" 226.5(b)(2)(ii)- Periodic statement 21 days prior to payment due date (but clarified credit card only with recent technical amendment) 226.7(b)(14) - Periodic statement and disclosure of deferred interest or similar program 226.9(c)(2) - Significant change in terms 226.9(g) - Increase in rate due to default or delinquency 226.10(b)(2)(ii) - Payment posting requirements 226.10(d) - Crediting of payments 226.16(f) - misleading terms in advertising 226.16(h) - deferred interest or similar offer - advertising 226.57(c) - marketing to college students
The Fed Register publication from October 21, 2009 re: proposed changes to Reg Z has a pretty nifty little chart about six pages in that breaks down the proposed revisions by type of credit - all open end, all open end not home secured, and credit card only. Really helpful.
_________________________
|
Return to Top
|
|
|
|
#1310303 - 12/21/09 05:50 PM
Re: Regulation Z - Open End changes - 7-1-10
SaaL
|
Gold Star
Joined: Mar 2008
Posts: 294
The Texas Hill Country
|
Related to our open end lines of credit (not credit card), my bank is considering increasing our line of credit rates across the board - for existing balances as well as new advances. Of course would provide the required notices (Texas requires 90 days so the change wouldn't be effective until some time in the 2nd quarter) and allow for opt out - and we still need to do some risk assessment. My reading of the proposed changes to reg z would tell me this (increasing rates on existing balances)is and will still be allowed even after the February changes for open-end as long as there's no relationship to a credit card - but I'd like to get some concurrence before we move forward.
Agree? Disagree?
_________________________
|
Return to Top
|
|
|
|
#1314406 - 12/29/09 03:42 PM
Re: Regulation Z - Open End changes - 7-1-10
SaaL
|
Gold Star
Joined: Mar 2008
Posts: 294
The Texas Hill Country
|
"bump" - anyone?
Related to our open end lines of credit (not credit card), my bank is considering increasing our line of credit rates across the board - for existing balances as well as new advances. Of course would provide the required notices (Texas requires 90 days so the change wouldn't be effective until some time in the 2nd quarter) and allow for opt out - and we still need to do some risk assessment. My reading of the proposed changes to reg z would tell me this (increasing rates on existing balances)is and will still be allowed even after the February changes for open-end as long as there's no relationship to a credit card - but I'd like to get some concurrence before we move forward.
Agree? Disagree?
_________________________
|
Return to Top
|
|
|
|
#1316722 - 01/04/10 03:15 PM
Re: Regulation Z - Open End changes - 7-1-10
SaaL
|
100 Club
Joined: Mar 2009
Posts: 124
|
Is no one out there struggling with the Ability to Repay on preapproved credit card offers? Or what about how the single amendment for Pricing Info should look for the website agreement (especially if single agreement serves multiple cards)?
|
Return to Top
|
|
|
|
#1317685 - 01/05/10 03:57 PM
Re: Regulation Z - Open End changes - 7-1-10
QCL
|
Diamond Poster
Joined: Mar 2002
Posts: 2,280
Far from Calif
|
I was thinking the gift card provisions are not effective until 8/22/2010. See the Reg E Proposal - comments were due by 12/21/09.
_________________________
The opinions expressed are mine and do not necessarily reflect those of my employer _._._._._._. A.S.A.P. Always Say A Prayer <><
|
Return to Top
|
|
|
|
#1318445 - 01/06/10 05:08 AM
Re: Regulation Z - Open End changes - 7-1-10
tyond
|
Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
|
Is no one out there struggling with the Ability to Repay on preapproved credit card offers? Or what about how the single amendment for Pricing Info should look for the website agreement (especially if single agreement serves multiple cards)? Pre-approved credit card offers usually come with a disclaimer that the offer is not guaranteed if the person does not meet the lender's criteria (Section 615 (d) of the Fair Credit Reporting Act.) What this means is that you will have to do more work to open these accounts.
_________________________
CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
|
Return to Top
|
|
|
|
#1318825 - 01/06/10 05:13 PM
Re: Regulation Z - Open End changes - 7-1-10
Princess Romeo
|
Diamond Poster
Joined: Sep 2008
Posts: 2,481
Midwest
|
I have read the post and now a little confused. Our bank used to offer HELOCs but has discontinued. We have some on the books still. Are there any requirements coming up in Feb that would affect us? As of now, we don't put any new open ended credit on the books just existing ones are left out there.
|
Return to Top
|
|
|
|
#1327684 - 01/20/10 09:51 PM
Re: Regulation Z - Open End changes - 7-1-10
ahkcompliance
|
Platinum Poster
Joined: Nov 2007
Posts: 767
|
REG Z is always confusing to me, especially open-end rules! We do not issue credit cards but do have lines of credit and HELOC's. Unless I have totally missed the mark...and this is so possible, it doesn't appear that PLC's and HELOC periodic statements will require changes to format. Am I right?
_________________________
Comments are strictly my own and not that of my employer.
|
Return to Top
|
|
|
|
#1328119 - 01/21/10 05:19 PM
Re: Regulation Z - Open End changes - 7-1-10
Still Smiling
|
Platinum Poster
Joined: May 2003
Posts: 832
southeast
|
NO - PLCs DO require new statements and contracts, and you may wish to look at the HELOC proposal for statement changes there, too. 5pm payment processing is required on all types of credit, by 2/22/2010 if not sooner (closed-end already in effect)
Last edited by Phoenix; 01/21/10 05:20 PM.
_________________________
From the end spring new beginnings. Pliny the Elder
|
Return to Top
|
|
|
|
#1328229 - 01/21/10 06:42 PM
Re: Regulation Z - Open End changes - 7-1-10
Phoenix
|
Platinum Poster
Joined: Nov 2007
Posts: 767
|
Thanks Phoenix. You mentioned HELOC "proposal for statement changes...exactly which version or proposal are you referring to? Sorry but I am having a hard time pulling all of this together with the different publications with varing dates
_________________________
Comments are strictly my own and not that of my employer.
|
Return to Top
|
|
|
|
|
|