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#1330829 - 01/26/10 03:27 PM
Re: Feb 22 Credit Card rules
trout22
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Power Poster
Joined: Aug 2001
Posts: 7,351
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Good grief....I hate to print that massive document.
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#1330855 - 01/26/10 03:47 PM
Re: Feb 22 Credit Card rules
trout22
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Power Poster
Joined: Aug 2001
Posts: 7,351
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What about the Opt-in for rate increases and the disclosure about the length of time to pay off the card at the minimum payment as well as the payment needed to pay off the card in 36 months? There's also the toll free number for credit counseling, and posting agreements on the website, rules for extending credit to cardholders under the age of 21?
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#1331002 - 01/26/10 05:32 PM
Re: Feb 22 Credit Card rules
swiggles
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Gold Star
Joined: Nov 2004
Posts: 313
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Oh yes, there are several others that will apply as of the Feb 22nd deadline that pertain to credit cards. I believe there were 25 total sections with an effective date of Feb 22, 2010. The above post includes a list for those of us who don't offer credit cards and only need to consider implications for lines of credit and other open-end credit (not home-secured).
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#1331104 - 01/26/10 06:45 PM
Re: Feb 22 Credit Card rules
trout22
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Platinum Poster
Joined: Aug 2005
Posts: 914
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I thought the 21 day rule only applied to cards and if that is true why does "226.5(b)(2) - periodic statements 21 days prior to due date" apply to all open end credit (even without a card)?
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#1331127 - 01/26/10 07:04 PM
Re: Feb 22 Credit Card rules
Sage
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Power Poster
Joined: Aug 2001
Posts: 7,351
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Would someone like to purchase a credit card portfolio???????
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#1332777 - 01/28/10 03:30 PM
Re: Feb 22 Credit Card rules
swiggles
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Power Poster
Joined: Aug 2001
Posts: 7,351
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Hasn't the opt out of a higher rate rule been in affect since last August? That isn't a February new rule is it?
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#1333705 - 01/29/10 03:24 PM
Re: Feb 22 Credit Card rules
swiggles
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Power Poster
Joined: Aug 2001
Posts: 7,351
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Hasn't the opt out of a higher rate rule been in affect since last August? That isn't a February new rule is it? Can anyone answer this question? I've been reading write-ups from various sites. About half state the opt out of a higher rate was effective August 20th (2009). The other half states it's effective February 22nd.
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#1334116 - 01/29/10 06:49 PM
Re: Feb 22 Credit Card rules
swiggles
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100 Club
Joined: Mar 2009
Posts: 124
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I have the opt out as part of the Aug 20th 2009 requirements, the change with February being that you now have to consider protected balances. Based on the final rules, some basic rate increase change in terms no longer require the right to reject.
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#1334118 - 01/29/10 06:51 PM
Re: Feb 22 Credit Card rules
tyond
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100 Club
Joined: Mar 2009
Posts: 124
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Does anyone have ideas about posting the pricing information and agreement on the website and to the Board?
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#1334160 - 01/29/10 07:18 PM
Re: Feb 22 Credit Card rules
tyond
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Power Poster
Joined: Aug 2001
Posts: 7,351
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Thanx, tyond! That explains my confusion. Our cards are all fixed rates. Occasionally, we'll raise the rate 1/2 percent depending upon what rates are doing. So I guess now, we'll have to provide an opt out when we do that. I could not find any model opt out language to add to our rate increase notice. Did I just miss it? I've sifted through the Appendices twice.
Your question regarding posting of the Agreement was also my next question. We have to send an "electronic" version of our agreements (we have three different agreements) to the Board. Sheesh! What address?
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#1337559 - 02/04/10 05:07 PM
Re: Feb 22 Credit Card rules
swiggles
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100 Club
Joined: Jul 2008
Posts: 148
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I'm curious as to how everyone else is dealing with the 5:00pm cutoff time for all open-end payments regardless of the payment type. This is an issue that we're having a tough time solving without involving a great deal of manual account adjustments every day.
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#1337563 - 02/04/10 05:12 PM
Re: Feb 22 Credit Card rules
CrookedVulture
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Gold Star
Joined: Nov 2003
Posts: 277
East Texas
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Thankfully, we are open that late at one location and give credit for date paid. We are small enough that we can hold payments made on Saturday and check for any late postings on Monday mornings. So far that has worked for us. I know that is probably no help to you, but that is our current way of dealing with this.
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#1337576 - 02/04/10 05:33 PM
Re: Feb 22 Credit Card rules
4newt
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100 Club
Joined: Mar 2009
Posts: 124
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Swiggles - there is a technical specs document that has requirements on how the file and information should be presented to the Board.
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#1337581 - 02/04/10 05:38 PM
Re: Feb 22 Credit Card rules
tyond
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Power Poster
Joined: Aug 2001
Posts: 7,351
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Swiggles - there is a technical specs document that has requirements on how the file and information should be presented to the Board. I discovered to my delight that we meet the de minimus exemption from the requirement in that we have far fewer than 10,000 accounts. 
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#1337601 - 02/04/10 05:50 PM
Re: Feb 22 Credit Card rules
swiggles
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100 Club
Joined: Mar 2009
Posts: 124
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Good for you, wish we were that lucky! I saw the below in the final, make sure you all can provide the below even if you fall under the 10,000 exception.
Similarly, the final rule provides that card issuers with fewer than 10,000 open credit card accounts are not required to submit agreements to the Board, and provides for other exceptions from the requirement to submit agreements. However, the Board
believes that the benefit of increased transparency associated with providing an individual cardholder with access to his or her specific credit card agreement is substantial regardless of the whether the card issuer is required to submit the agreement
to the Board for posting on the Board’s Web site. The Board believes that this benefit of increased transparency for consumers outweighs the administrative burden on issuers of
providing such access, and therefore § 226.58(e) in the final rule does not include the exceptions from the requirement to submit agreements to the Board under § 226.58(c).
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#1338037 - 02/04/10 10:44 PM
Re: Feb 22 Credit Card rules
trout22
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Member
Joined: Feb 2010
Posts: 72
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The rules for 2/22/10 only apply to revolving credit lines correct? We don't offer those currently, but we do have some on the books. Do the rules only apply to loans opened 2/22 and after or do we have to do something with the ones we already have?
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#1338409 - 02/05/10 03:43 PM
Re: Feb 22 Credit Card rules
DCollins
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Power Poster
Joined: Aug 2002
Posts: 3,094
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Look at the model disclosures - it's on there.
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#1338511 - 02/05/10 04:19 PM
Re: Feb 22 Credit Card rules
kiemo
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Power Poster
Joined: Aug 2002
Posts: 3,094
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Trout 22
Just returned from a webinar from BVS Compliance Director, Jeff Thorp..he claims that a cut-off for customer payments will pass compliance as long as it is a banks' end of day. i.e. (3:00p.m. on a due date can be considered latest time to be 'on time')
3:00 will not be reasonable unless you can backdate the pmt
226.10(ii) Setting reasonable cut-off times for payments to be received by mail, by
electronic means, by telephone, and in person (except as provided in paragraph (b)(3) of
this section), provided that such cut-off times shall be no earlier than 5 p.m. on the
payment due date at the location specified by the creditor for the receipt of such
payments;
Switching gears...He also discussed the term 'Non variable rate' as a perferrable term to fixed or variable so that ' a bank has the right to change a rate from time to time'. We had not heard this anywhere, nor can I find this term in actual reg or from any other source...Anyone else ???
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Opinions are my own and not of my employer.
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#1338607 - 02/05/10 04:58 PM
Re: Feb 22 Credit Card rules
DCollins
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Diamond Poster
Joined: Dec 2003
Posts: 1,342
Wisconsin
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We offer personal unsecured lines of credit. Am I correct in assuming that the 2/22/10 rules apply to these? Specifically, I'm wondering about the changes in the format of periodic statements.
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#1338639 - 02/05/10 05:16 PM
Re: Feb 22 Credit Card rules
tyond
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Diamond Poster
Joined: Mar 2002
Posts: 2,269
Far from Calif
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Good for you, wish we were that lucky! I saw the below in the final, make sure you all can provide the below even if you fall under the 10,000 exception.
Similarly, the final rule provides that card issuers with fewer than 10,000 open credit card accounts are not required to submit agreements to the Board, and provides for other exceptions from the requirement to submit agreements. However, the Board
believes that the benefit of increased transparency associated with providing an individual cardholder with access to his or her specific credit card agreement is substantial regardless of the whether the card issuer is required to submit the agreement
to the Board for posting on the Board’s Web site. The Board believes that this benefit of increased transparency for consumers outweighs the administrative burden on issuers of
providing such access, and therefore § 226.58(e) in the final rule does not include the exceptions from the requirement to submit agreements to the Board under § 226.58(c). Okay, so I was relieved to read in 226.58 the de minimum exception for posting agreements to the Board since we have fewer than 10,000 open accounts. However, I want to make sure that I am correct in my understanding that we get the same exception for posting to our website? It seems like the deminimus applies to both (pg. 452), but then it's not so clear in other parts of the final rule.
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