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#1338733 - 02/05/10 06:21 PM Re: Feb 22 Credit Card rules ahou
tyond Offline
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ahou - are the model disclosures being referenced for the application and account opening table disclosures?

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#1338735 - 02/05/10 06:22 PM Re: Feb 22 Credit Card rules ahou
kiemo Offline
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kiemo
Joined: Jan 2009
Posts: 267
MidUS
Thank you ahou!! I did not understand where his information was coming from--we won't be signing up for his webinars that is for sure ! We were better off with our own info deciphering..

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#1338809 - 02/05/10 06:59 PM Re: Feb 22 Credit Card rules tyond
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
There are model disclosures for application, acct opening and periodic statements.
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#1339035 - 02/05/10 09:04 PM Re: Feb 22 Credit Card rules CalifDreamin
CalifDreamin Offline
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CalifDreamin
Joined: Mar 2002
Posts: 2,215
Far from Calif
Originally Posted By: FlamingoGal
Originally Posted By: tyond
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.


Sorry - I asked that too soon. 226.58(e) makes it clear that even if we have less than 10,000 open accounts we are going to have to either post the agreement or have a readily available phone number for them to call and request it.
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#1339055 - 02/05/10 09:15 PM Re: Feb 22 Credit Card rules CalifDreamin
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
[Sorry - I asked that too soon. 226.58(e) makes it clear that even if we have less than 10,000 open accounts we are going to have to either post the agreement or have a readily available phone number for them to call and request it.]


It says you must either post the accountholders individual agreement on your web site or promptly provide a copy of the cardholder's agreement.

If you choose to provide upon request you have to do 2 things - give the cardholder the ability to request via the web site and by calling a readily available telephone number, which is displayed on the web.
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#1339765 - 02/08/10 09:35 PM Re: Feb 22 Credit Card rules ahou
Hi Offline
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Joined: Jun 2003
Posts: 54
Pricing information for agreements under 226.58(e)..

(ii) Pricing information. (A) Pricing information must be set forth in a single addendum to the agreement that contains only the pricing information.

Does this mean an attachment or can it be on the back page of the agreement? Also, does the pricing information have to be in tabular format like the application and account opening disclosures?

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#1342290 - 02/11/10 09:28 PM Re: Feb 22 Credit Card rules trout22
Still Smiling Offline
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Joined: Nov 2007
Posts: 767
Trout22,
Did you ever recieve a response on the 5:00 cut off time. We also close before 5:00. It is my understanding that this also applies to All open end credit plans, which to me includes unsecured lines of credit, HELOC's, and Overdraft lines. Help!
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#1342647 - 02/12/10 02:43 PM Re: Feb 22 Credit Card rules Still Smiling
CrookedVulture Offline
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Joined: Jul 2008
Posts: 148
We are updating our agreements and statements to indicate that payments made in person should be made only at one of our branch locations. That location will accept payments until 5:00 for same day processing. All other locations will be considered non-conforming and our normal cutoff time will apply.

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#1343113 - 02/12/10 08:27 PM Re: Feb 22 Credit Card rules CrookedVulture
smith Offline
Member
Joined: Jun 2004
Posts: 69
Nebraska
Does anyone know if 226.9(e) applies only to credit cards?

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#1344614 - 02/17/10 05:38 PM Re: Feb 22 Credit Card rules smith
ItsJustMe Offline
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Joined: Dec 2009
Posts: 285
New York
We have decided to post our credit card agreements & pricing info for all of our credit card products, even though some of them are no longer being offered but some customers still have open. We decided to do this in hopes of cutting down on phone call requests. I have a question as to the effective date relating to the pricing information required to be posted on our web site. 226.58 states that we must post the same pricing information on our web site that we provide to the Feds…the pricing information required to be on the Fed site must be as of 12/31/2009. Do you interpret the rule to mean that the pricing information we post on our site must also be as of that effective date? This is outdated information compared to what we can post immediately. Opinions

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#1344639 - 02/17/10 06:01 PM Re: Feb 22 Credit Card rules ItsJustMe
tyond Offline
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Joined: Mar 2009
Posts: 124
I think the type of information and format is to be consistent but the information can be updated. Our current card agreement and pricing information is different than what we are submitting to the board as of 12/31. We had to change some terms to be compliant with 2/22. I copied the below:

Section 226.58(d)(4) incorporates provisions from proposed Appendix N, paragraph 2, stating that an issuer must update the agreements posted on its Web site at least as frequently as the quarterly schedule required for submission of agreements to the
Board. If the issuer chooses to update the agreements on its Web site more frequently,the agreements posted on the issuer’s Web site may contain the provisions of the agreement and the pricing information in effect as of a date other than the last business
day of the preceding calendar quarter.

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#1344649 - 02/17/10 06:14 PM Re: Feb 22 Credit Card rules tyond
ItsJustMe Offline
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Joined: Dec 2009
Posts: 285
New York
Thank you for that information, tyond! This is exactly what I needed...thanks again!

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#1345791 - 02/18/10 10:38 PM Re: Feb 22 Credit Card rules CSB98
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
Originally Posted By: CSB1
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.


CSB1, did you ever get an answer to this? I'm wondering if there will be changes to the format requirements for non-credit card accouts (either in February or in July). I know there are changes for credit cards, but I'm not sure about HELOCs, OD lines, Personal unsecured lines, etc.
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#1345823 - 02/18/10 11:06 PM Re: Feb 22 Credit Card rules Deena
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
Statement formatting requirements are required for cr cards and non-HELOC open-end products such as unsecured lines of credit. (effective in July)
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#1346011 - 02/19/10 03:23 PM Re: Feb 22 Credit Card rules ahou
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
Thanks very much.
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#1347505 - 02/23/10 03:59 PM Re: Feb 22 Credit Card rules Deena
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,333
I'm confused.

Model Forms G-18(F) and G-18(G) both say "bank credit card account statement." Where does it say that these model forms apply to non-credit-card open-end non-heloc accounts?

Also, what is the difference in these two model forms?
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