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#1311576 - 12/22/09 06:50 PM Feb 22 Credit Card rules
Baker Offline
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Joined: Nov 2005
Posts: 792
Washington State
I can not find where the Feb 22, 2010 rules implemented under the credit card act are addressed in reg Z or aa. The card act seems vague, can any one point me in the right direction?

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Lending Compliance
#1311890 - 12/22/09 09:21 PM Re: Feb 22 Credit Card rules Baker
cloudy Offline
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Do you have the 841 pages issued by the Federal Reserve System on 9/30/09? Starting on page 313 the CARD Act changes are broken out how they will be implemented into reg z.

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#1312490 - 12/23/09 05:50 PM Re: Feb 22 Credit Card rules cloudy
Baker Offline
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Washington State
Isn't this just a proposed rule at this time?

I may not have it. The only thing I could find is the Federal Reserve proposed rules for Truth in Lending issued October 21, 2009. Docket No. R-1370.

Is this what you are referring to or is it something else. This one appears to be just over 300 pages. Can you send the link to what you are referring?

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#1320851 - 01/08/10 03:42 PM Re: Feb 22 Credit Card rules Baker
cloudy Offline
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It is just a proposal at this time, but not much will change. The 300 pages you found is the same as the 841 pages, just in a different layout.

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#1321420 - 01/08/10 09:25 PM Re: Feb 22 Credit Card rules cloudy
Jan94 Offline
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USA
I'm having a hard time determining if any of the Feb 22nd changes are affecting non-credit card open-end (i.e. personal revolving lines, etc.) Looking at 226.10 on the Cut Off Times. One document I have states for other than credit cards, the effective date is July 1, 2010 but someone told me that the February 22nd date also applies to non-credit cards. Do any of the Feb 22nd changes affect non-credit cards? Thank you.

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#1321438 - 01/08/10 09:42 PM Re: Feb 22 Credit Card rules Jan94
ahou Offline
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ahou
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The final rule may eliminate that requirement for non cr card accounts.
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#1323269 - 01/12/10 09:06 PM Re: Feb 22 Credit Card rules ahou
ahkcompliance Offline
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Midwest
Do the February changes affect non-credit card accounts?

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#1323300 - 01/12/10 09:24 PM Re: Feb 22 Credit Card rules ahkcompliance
RR Joker Offline
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no
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#1323303 - 01/12/10 09:28 PM Re: Feb 22 Credit Card rules RR Joker
ahkcompliance Offline
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Midwest
Is there a time limit rate changes for HELCOs must be sent? Is that 45 days?

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#1323675 - 01/13/10 05:06 PM Re: Feb 22 Credit Card rules RR Joker
4newt Offline
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Posts: 277
East Texas
RR Joker - Does your "no" mean that non-credit card open end loans are not affected by this, or that the Feb. 22 date does not apply?

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#1323903 - 01/13/10 07:00 PM Re: Feb 22 Credit Card rules 4newt
trout22 Offline
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From what I have seen so far, the majority of the Feb 22nd portion are directed specifically at credit cards.

If anyone has a list/resource of Feb 22nd CARD Act requirements affecting non-credit card open end loans I would be grateful as well.

If you check out this link, you can get the FRB press release from today with a quick summary and the final rule (all 1155 pages of it!)

http://www.federalreserve.gov/newsevents/press/bcreg/20100112a.htm

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#1323962 - 01/13/10 07:27 PM Re: Feb 22 Credit Card rules trout22
4newt Offline
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From what I can see on pages 22-23 of the lovely 1155 page document, there are 17 provisions that effect "credit card accounts under an open-end (not home secured) consumer credit plan" and 9 and a part that effect "ALL open-end (not home-secured) consumer credit plans". Do the "ALL open-end (not home-secured) consumer credit plans" sections really pertain to all open-end, etc. or is that part of the President's November "opps, I meant credit cards only" and it really doesn't effect a personal line of credit that has no credit card????

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#1323984 - 01/13/10 07:41 PM Re: Feb 22 Credit Card rules 4newt
ahkcompliance Offline
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Midwest
My thoughts were along the same lines of jnewton. Do they really pertain to all open ended plans...

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#1324018 - 01/13/10 08:03 PM Re: Feb 22 Credit Card rules ahkcompliance
ahkcompliance Offline
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Midwest
This may be dumb question but I can't find it. On the chart on page 22-23 it says 226.7(b)(14) relates to all open ended credit. In the amendments I only see up to (b)(13)? what does 14 deal with?

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#1324030 - 01/13/10 08:10 PM Re: Feb 22 Credit Card rules ahkcompliance
4newt Offline
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East Texas
On page 133 of the same document it goes into that. Granted, I have only skimmed it, but I beleive it pertains to deferred interest and when it is payable.

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#1324035 - 01/13/10 08:13 PM Re: Feb 22 Credit Card rules ahkcompliance
trout22 Offline
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Posts: 313
Here's what I'm hung up on... along the same lines...

This is a footnote related to the effective dates of Feb 22 vs July 1 - found on page 8 if you're reading along.

"The Board notes that the provisions regarding advance notice of changes in terms and rate increases set
forth in § 226.9(c)(2) and (g) apply to all open-end (not home-secured) plans. The Credit Card Act’s
requirements regarding advance notice of changes in terms and rate increases, as implemented in this final
rule, apply only to credit card accounts under an open-end (not home-secured) consumer credit plan. In
order to have one consistent rule for all open-end (not home-secured) plans, compliance with the
requirements of § 226.9(c)(2) and (g) (except for specific formatting requirements) is mandatory for all
open-end (not home-secured) plans on February 22, 2010."

So, I'm reading that to say that even though initially these two sections would pertain to only credit cards, to be consistent we will on Feb 22 address all open-end (not home-secured) loans the same way, so per the final rule § 226.9(c)(2) and (g) applies to ALL.

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#1324086 - 01/13/10 08:33 PM Re: Feb 22 Credit Card rules trout22
ahkcompliance Offline
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Posts: 2,474
Midwest
That is the way I take it. The only thing we will have to worry about is our overdraft line of credit since HELOCs don't apply.

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#1324346 - 01/14/10 05:00 AM Re: Feb 22 Credit Card rules ahkcompliance
Princess Romeo Offline

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So........., 1,155 pages - some nice light reading for the weekend!
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Regulations are a poor substitute for ethics.
Just sayin'

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#1324347 - 01/14/10 05:20 AM Re: Feb 22 Credit Card rules Princess Romeo
Kathleen O. Blanchard Offline

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Originally Posted By: Princess Rooney
So........., 1,155 pages - some nice light reading for the weekend!

I just about passed out when I saw the number of pages. tired
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#1327195 - 01/20/10 04:10 PM Re: Feb 22 Credit Card rules Kathleen O. Blanchard
trout22 Offline
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Joined: Nov 2004
Posts: 313
My most immediate concern is addressing the 5:00 PM cut-off safe harbor. Most banks in my area are 3:00 or 4:00 cut-off for end of day processing. How do we comply with this? My thoughts are either A) Rely on tellers to locate open-ended credit payments taken between end of day processing and 5:00 safe harbor that would be considered late if processed next day instead of current day; or B) Do away with late charges on all open-ended credit.

We sent a notice to consumers back in September which clearly stated our policy for conforming and non-conforming payments, however, that all appears to be for not with the final rule publishing a 5:00 safe harbor.

Am I missing something here? Anyone else with a cut-off time prior to 5:00 PM (local time) that has a solution in place yet??

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#1327230 - 01/20/10 04:33 PM Re: Feb 22 Credit Card rules trout22
ahkcompliance Offline
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Joined: Sep 2008
Posts: 2,474
Midwest
I'm going over the ruling again, and now confused. From what I just read, are overdraft lines of credit exempt from the new credit card ruling? I thought from what I read on pages 25-27, those products were exempt.

Am I missing something?

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#1327356 - 01/20/10 05:40 PM Re: Feb 22 Credit Card rules ahkcompliance
trout22 Offline
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Posts: 313
I believe ODP products are exempt. We don't offer those, so I haven't spent much time researching such an option, but it seems that I recall reading that they were exempted from this provision.

However, all open-ended lines of credit (which we do offer - similar to the overdraft lines of credit mentioned above) would be included as long as they are not real-estate secured. That's my take - and why I'm concerned with the Feb 22nd mandatory compliance date.

I'll update my post if I come across the exact verbiage that led me to this conclusion...

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#1330756 - 01/26/10 02:46 PM Re: Feb 22 Credit Card rules trout22
swiggles Offline
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swiggles
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Posts: 7,351
Originally Posted By: trout22
From what I have seen so far, the majority of the Feb 22nd portion are directed specifically at credit cards.

If anyone has a list/resource of Feb 22nd CARD Act requirements affecting non-credit card open end loans I would be grateful as well.

If you check out this link, you can get the FRB press release from today with a quick summary and the final rule (all 1155 pages of it!)

http://www.federalreserve.gov/newsevents/press/bcreg/20100112a.htm


Has this been published in the Federal Register? I cannot find it.
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#1330821 - 01/26/10 03:21 PM Re: Feb 22 Credit Card rules swiggles
trout22 Offline
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Joined: Nov 2004
Posts: 313
Here is my list of ALL open-end credit going into effect on Feb 22nd.

226.5(b)(2) - periodic statements 21 days prior to due date
226.9(c)(2) - written notice 45 days prior to change in terms
226.9(g) - written notice to each consumer with rate increase due to delinquency/default/penalty
226.10(b)(2)(ii) - crediting of payments - 5:00 deemed 'reasonable' cut-off time
226.10(d) - crediting of payments - mailed payments are not late if payment date falls on a date the bank does not receive mail, it must be processed on the next banking day with no late fees
226.16(f)/226.5(a)(2)(iii) - advertising and restrictions on the use of the term 'fixed'

Those are the 7 related items I am looking at for Feb 22nd, with 2 others - 226.7(b)(14) on two cycle billing and accrued interest, and 226.16(h) on disclosure of deferred interest - to follow on July 1 for all open-end consumer credit plans...

Please correct me if I'm wrong, but this is what we're building our plans around.

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#1330827 - 01/26/10 03:25 PM Re: Feb 22 Credit Card rules swiggles
trout22 Offline
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Joined: Nov 2004
Posts: 313
Originally Posted By: swiggles

Has this been published in the Federal Register? I cannot find it.


Not that I've been able to locate...

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