Page 9 of 14 1 2 7 8 9 10 11 13 14
Thread Options
#1383878 - 04/29/10 07:49 PM Re: Regulation Z - Open End changes - 7-1-10 ahou
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,634
The Swamp
oh nice..that section isn't even in the final rule table of applicable sections..great, just great! It skips from .5 to .7!
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
Lending Compliance
#1384100 - 04/30/10 12:55 PM Re: Regulation Z - Open End changes - 7-1-10 RR Joker
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 961
PA
Originally Posted By: RR joker
oh nice..that section isn't even in the final rule table of applicable sections..great, just great! It skips from .5 to .7!


My sentiments exactly. We don't issue credit cards, so what I did was go to that table of what applies to all open-end credit or open-end (not home secured) and begin to figure out what we needed to do. Now I feel like I'm missing relevant sections - such as these disclosure rules and maybe periodic statement rules?? crazy

Return to Top
#1384290 - 04/30/10 03:42 PM Re: Regulation Z - Open End changes - 7-1-10 AuditorK
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,634
The Swamp
great fun, huh!
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1385145 - 05/03/10 08:11 PM Re: Regulation Z - Open End changes - 7-1-10 RR Joker
Shopgirl Offline
Diamond Poster
Joined: Aug 2003
Posts: 1,264
Southeast
Okay....I'm definitely behind in my new reg reading, but have finally started on the 7/1/10 Reg Z revisions. And yes.....I'M SOOOOO CONFUSED! HELP ME!!!!

we are a very vanilla bank and don't have credit cards. I have printed both the Jan. 29, 2009 Federal Register and the Feb 22, 2010 Federal Register. Which is it, or is it both? The Feb 22 register, I do see a table in there of the sections that must be complied with by 7/1/10, but from what I can tell, there's really nothing there for us other than a bit of jibberjash......the most I can tell from that is the 45-day requirement. What am I missing there?
As far as the Jan 2009 register, was that one retracted? I thought I had read that somewhere but maybe again....I'm confused. Because I see you guys talking about periodic statements........

Wait a minute....I might have it.....Let's see, the January 2009 register must still be complied with by 7/1/10; however the February 2010 register are those new provisions addressing the Credit Card Act that will also have to be complied with by 7/1/10......Correct????
Last edited by Shopgirl; 05/03/10 08:16 PM.
Return to Top
#1385319 - 05/04/10 01:09 PM Re: Regulation Z - Open End changes - 7-1-10 Shopgirl
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,634
The Swamp
Ya know, I'm not really sure. This one was so botched up, I mean really! I ended up mostly following the regulation posted here. I have done a table for our Ready Reserve (bounce protection LOC), changed the Notice of Changes to 45 days and further described our FC calculation info.

We decided to do away with our OE LOC's (unless over $25K)

I'm wondering just WHAT ELSE AM I MISSING. I know the statement will change and I'm not sure how we are going to handle that considering it's such a simple product and normally just appears in with the deposit account it's tied to. I'm hoping (assuming) JH is working on that issue!
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1385362 - 05/04/10 02:09 PM Re: Regulation Z - Open End changes - 7-1-10 RR Joker
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
I have been so caught up with other things going on like Reg E and just got done with a compliance exam. I am now ready to start in on the 7/1/2010 changes for Reg Z. We do not issue our own credit cards, they are outsourced. We do have a two open end products available, overdraft line of credit and HELOCs. From what I understand, the periodic statement requiret for HELOCs is still in the works but what changes do we need to comply with for the overdraft line of credit for periodic statements?

Return to Top
#1385529 - 05/04/10 04:11 PM Re: Regulation Z - Open End changes - 7-1-10 ahkcompliance
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,634
The Swamp
Let's see shopgirl...I did dig this up:

12-08 - final Reg Z rules to both content and format of OE (not home secured) disclosures eff 7-1-2010. 1-12-2010 board issued final rules implementing those portions of the CC Act, eff 2-22-10. The 1-2010 rule accelerated the effective date (2-22-10) of a number of the Change-in-Terms and advertising changes.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1385972 - 05/04/10 10:48 PM Re: Regulation Z - Open End changes - 7-1-10 ahkcompliance
mmumm Offline
100 Club
Joined: Jul 2008
Posts: 163
Santa Cruz, California
we are just like you - we have credit cards, but issued through another company, and we do HELOCs and overdraft lines. I thought I was all up to speed with the Reg Z changes, and thought that the only ones that affect us took place on Feb. 22nd, however, someone told me there are July 1st changes that will affect us too! Anyone know what these are? Any help is GREATLY appreciated!

Return to Top
#1386022 - 05/05/10 12:07 PM Re: Regulation Z - Open End changes - 7-1-10 mmumm
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,634
The Swamp
Your OE (not re secured) LOC's will need a tabular format, I'm using G-17 for our overdraft lines.

Your statement layout will change.

HELOC's are not final yet. (unless I missed something along the way which is entirely possible at this point!)
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1386194 - 05/05/10 03:04 PM Re: Regulation Z - Open End changes - 7-1-10 RR Joker
Raquel Offline
100 Club
Joined: Aug 2007
Posts: 128
This is the listing that I have compiled of 7/1/2010 changes that affect Home Equity Lines of Credit and it looks like most of the changes involve choices:

Account-opening disclosures - 226.6(5) may use Model Form G-3 Long Form Billing-Error Rights (same as current form) or use new model form G-3(A) for plans other than Home-Equity.

Subsequent disclosure requirements – 226.9(a)(2) which pertains to the short-form billing rights says that for Home Equity plans Model Form G-4 (same as current form) can be used or G-4(A) (form for plans other than Home Equity)

Periodic statement – 226.7
Creditors who offer home equity plans subject to 226.5b may use periodic statement requirements of 226.7(a) or alternatively use any of the requirements of (b) for open-end not home secured plans. Requirements of 226.7(a) are basically the same as the current requirements with the following changes:

1. A new exception was added as 226.7(a)(4)(ii) under periodic rates: An annual percentage rate that differs from the rate that would otherwise apply and is offered only for a promotional period need not be disclosed except in periods in which the offered rate is actually applied.
2. Under section 226.7(a)(7) Annual percentage rate, the phrase “At a creditor’s option” was added. However, if the creditor elects not to do this disclosure they must comply with 226.7(b)(6) regarding disclosure of interest and fees.
3. Under 226.7(a)(8), terminology was changed from “Free-ride period” to “Grace Period”.

Return to Top
#1386370 - 05/05/10 05:47 PM Re: Regulation Z - Open End changes - 7-1-10 Raquel
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
I think we will use G17d for our account opening disclosure for the LOC. What model should the LOC follow for periodic statement?

Return to Top
#1386436 - 05/05/10 07:04 PM Re: Regulation Z - Open End changes - 7-1-10 ahkcompliance
Raquel Offline
100 Club
Joined: Aug 2007
Posts: 128
G17d will be the one we use for our personal LOC's also. As for periodic statement, the only complete model forms in Appendix G are are G-18(F) and G-18(G)and both of these are for credit cards so I think we are on our own for LOC statements. Or perhaps I should say - at the mercy of the company used for processing.

Return to Top
#1386516 - 05/05/10 08:16 PM Re: Regulation Z - Open End changes - 7-1-10 Raquel
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,634
The Swamp
Yes, I believe JH will be handling the statement end of things for us, so I haven't looked to closely at that.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1386527 - 05/05/10 08:31 PM Re: Regulation Z - Open End changes - 7-1-10 RR Joker
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
Anyone a Fiserv bank?

Return to Top
#1386671 - 05/06/10 01:15 PM Re: Regulation Z - Open End changes - 7-1-10 ahkcompliance
Soccer Offline
Platinum Poster
Joined: Jan 2010
Posts: 995
Utopia
Yes we are a Fiserv bank, have you received any communication from them in regards to the upcoming changes?
_________________________
Everything happens for a reason

Return to Top
#1386795 - 05/06/10 03:40 PM Re: Regulation Z - Open End changes - 7-1-10 Soccer
Cowboys Fan Offline
Power Poster
Joined: Dec 2002
Posts: 4,573
SC
Fiserv/ITI - haven't heard anything yet.
_________________________

Return to Top
#1386820 - 05/06/10 04:04 PM Re: Regulation Z - Open End changes - 7-1-10 Cowboys Fan
river girl Offline
Diamond Poster
Joined: Nov 2004
Posts: 1,004
Our credit card statements cut on the 24th of the month.
Is this an issue for the new requirement to disclose fees and interest for the month to date and the year to date?

Return to Top
#1386953 - 05/06/10 05:59 PM Re: Regulation Z - Open End changes - 7-1-10 river girl
Raquel Offline
100 Club
Joined: Aug 2007
Posts: 128
226.7(b)(6)(ii) and (iii) refer to disclosing both interest and fees for statement period and calendar year to date. These sections also reference Sample G-18(A) which uses terminology of "Total fees for this Period" and "Total Interest for this Period". Following the language and format in G-18(A)should provide for compliance regardless of the statement date.

Return to Top
#1387291 - 05/06/10 08:49 PM Re: Regulation Z - Open End changes - 7-1-10 Raquel
river girl Offline
Diamond Poster
Joined: Nov 2004
Posts: 1,004
Thanks Raquel.
I have another question dealing with terminolgy changes.

We are updating the credit card application disclosure and account opening disclosure to replace the term "grace period" with "how to avoid paying interest on purchases".

We are also updating the front side of the periodic statement to replace "finance charge" with "interest charge" and "other charges" with "fees".

This might be a silly question but..... Do we also need to replace all of those terms on the account agreement and the back of the periodic statement where we explain how to compute the finance charge?

Return to Top
#1387382 - 05/06/10 10:31 PM Re: Regulation Z - Open End changes - 7-1-10 river girl
ahou Offline
Power Poster
ahou
Joined: Aug 2002
Posts: 3,094
The application disclosures and the use of the heading "How to Avoid Paying Interest on Purchases" is used when all types of purchases have a grace period.

For the account opening disclosures, if a grace period is offered on all features of an account you use "How to Avoid Paying Interest". However, if a grace period is not offered on all features (such as cash advances), you must use "Paying Interest".
_________________________
Opinions are my own and not of my employer.

Return to Top
#1387567 - 05/07/10 02:20 PM Re: Regulation Z - Open End changes - 7-1-10 Soccer
upstateNY Offline
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
Fiserv SourceOne bank here. I have a communication from them about the new statement format. They are NOT following the models. Appears they are only meeing the basic requirements. Not in the office today. But could share more on MOnday if you contact me.

Return to Top
#1387770 - 05/07/10 05:00 PM Re: Regulation Z - Open End changes - 7-1-10 upstateNY
Mariela Offline
New Poster
Joined: Mar 2010
Posts: 8
Do we need to disclose on the statements the new APR if the rate changes on i.e. Variable rate Lines of Credit at any time during the statement cycle.
(i.e. Eff 07/20 Loan Interest rate change from 5.00% to 6.00%)

Return to Top
#1388348 - 05/10/10 03:22 PM Re: Regulation Z - Open End changes - 7-1-10 Still Smiling
Mortimer Offline
Member
Joined: Nov 2009
Posts: 65
In regards to credit card apps and solicitations, we do not currently issue credit cards, but we do provide "take home" applications on behalf of another card issuer. We do not currently accept completed applications to funnel through to the card issuer, but we direct the customer to either contact or mail the completed application to the issuing bank. Because of our limited involvement in this process, are we still subject to the disclosure requirements that go into effect on 7/1? What if we were to "funnel" applications through to the card issuer? This is an idea they have asked us to entertain.

Return to Top
#1388535 - 05/10/10 06:43 PM Re: Regulation Z - Open End changes - 7-1-10 Mortimer
Phoenix Offline
Platinum Poster
Phoenix
Joined: May 2003
Posts: 832
southeast
Look at this from the customer's perspective - if the actual card issuer does NOT make appropriate changes by 7/1/10 - will your customers blame you or just the card issuer?
_________________________
From the end spring new beginnings.
Pliny the Elder

Return to Top
#1389296 - 05/11/10 07:55 PM Re: Regulation Z - Open End changes - 7-1-10 Phoenix
Bullseye Offline
Platinum Poster
Bullseye
Joined: Jan 2004
Posts: 968
I have a question - Do fees for expedited services need to be disclosed in the table provided at account opening? Examples would be fees for an expedited payment or card. I cannot find in the regulation where its required, but a seminar presenter stated they were required to be in the table. Thoughts?

Thanks.

Return to Top
Page 9 of 14 1 2 7 8 9 10 11 13 14

Moderator:  Andy_Z