http://www.federalreserve.gov/newsevents/press/bcreg/20090723a.htm

"May you live in interesting times...." Ah -

Thanks so very much!

On the cr card application/solicitation the bank has to disclose a "return pmt fee". The reg describes it as a fee to return a payment. Would this be an NSF fee they are referring to?

1. In regard to a change in term notice, if we are eliminating the over the limit fee because we will no longer allow the customer to exceed the cr limit on his cr card, do we have to send a chg in term notice?

I'm talking myself out of having to send the change in term notice because we are eliminating the over the limit fee. Does anyone have an opinion on this? Mgmt is breathing down my neck.

We've eliminated the fee as well....are not sending a notice. The change is to the customer's advantage. If anyone disagrees, please speak up.

we will be changing how excess payments are applied, eliminating the over limit fee, eliminating the floor, providing a phone number to call for counseling, adding the how long it will take to pay off the loan box to statements, etc...
Seems everything is to the consumer's advantage so from a regulatory standpoint, do we have to send a notice?
From a good PR standpoint, I say we should but management only wants to know if it is required to send.
Thanks

Can anyone give me some insight on how stored value/gift cards will be affected and when???? I can't find it anywhere......

There is a proposed Reg E rule (as a result of the Cr Card Act) out, but has not yet been made final.

I am now cautious on not sending any form of notice based on sec. 226.9e, where it mentions any card issuer that has changed/amended any term required to be disclosed but did not provide notice should do so before the account renews. It seems easier to send out a notice during the time of change to everyone vs. tracking on individual reissue date to send notice 30 days prior.

Help me please...I've been working 12+ hours a day plus weekends, holidays and my last 5 vacation days of 2009 trying to implement all these new regulations. For unsecured lines of cr periodic statements, don't they have to be in the new format and don't we have to aggregate fees & int charges for the period and YTD?

Yes - for non-card open-end accounts, by 7/1/2010.

I have a question regarding the payments section 226.10(b)(2)(ii), our current cut off time is 4pm. Does this mean we will have to change it to 5pm?

NEW QUESTION - So has anyone got the BOL e-mail for training that says, "New Final Credit Card Act applies to HELOCS"? What? Does that just mean the sections that are "all open-end consumer credit plans" will be applicable?

It's not saying everything applies to HELOCs, correct?

If so, then I've totally missed the boat. Please let me know what you all think. Thanks! :o)

So, have I missed it, or has there been a final rule published in reference to the proposal for HELOCs that was published 8-26-09?!?

Final rule has not come out yet.

thanks!

There are three sections of the current final rule that DO apply to HELOC. See page 6 of the 'double spaced version' that says this.

Provisions of January 2009 Regulation Z Rule Applicable to HELOCs.
The final rule incorporates several sections of the January 2009 Regulation Z Rule that are applicable only to home-equity lines of credit subject to the requirements of § 226.5b (HELOCs). In particular, the final rule includes new §§ 226.6(a), 226.7(a) and
226.9(c)(1), which are identical to the analogous provisions adopted in the January 2009 Regulation Z Rule. These sections, as discussed in the supplementary information to the January 2009 Regulation Z Rule, are intended to preserve the existing requirements of Regulation Z for home-equity lines of credit until the Board’s ongoing review of the rules that apply to HELOCs is completed.

could you so kindly post a link to that specific publication? Thanks in advance!

I don't have a link to the double-spaced document, but here's a link to the pdf. I think the sections applicable to HELOCs were just redesignations of existing requirements - nothing new. If I'm wrong, hopefully someone will correct me.

ah...I hope so...one less thing to dig through, but thanks for the link.

Deena, your link is to the 1/29/09 Federal Register which the FRB has announced they are withdrawing. I think the double-spaced document StevenD was referring to is the non-Federal Register format of the Reg. Z final rule that is effective 2/22/2010. Here's a link to it. http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20100112a1.pdf It is 1155 pages. Page 6 contains the wording StevenD quoted. This has not yet been published in the Federal Register.

If your bank is a member of the ABA and you have registered to access member-only content on their website, they have some good resources on the Credit CARD Act and Regulation Z amendments. http://www.aba.com/Members+Only/Regulatory/CreditCardAct.htm

They just posted a staff analysis today of the non-credit card provisions of the Reg. Z rule that is effective 2/22/10 with some provisions effective 7/1/10.

I wasn't sure because StevenD referenced the January 09 rule and that rule did have sections applicable to HELOCS (just redesignations), so I thought that's what he meant. It's so hard to keep all these Reg Z rules straight and unfortunately, we're not members of ABA so I can't access the materials you mentioned.

OK - I'm looking for any insight on how credit card issuers are treating the young consumer provisions. I am having a hard time noting the difference for account opening process - If a young consumer qualifies based on Ability to Pay criteria, they can be issued an account (Same if a consumer older than 21 applied). If a young consumer DOES NOT qualify based on Ability to Pay criteria, they are not issued an account (Same if a consumer older than 21 applied). Is the difference that if a young consumer that DOES NOT qualify as an individual, is now required to have a co-applicant that is at least 21 yrs old??? What if you had two applicants that were both young consumers and only one qualified????