I've been hearing that a non-home secured line of credit such as an overdraft line of credit or unsecured credit line (without an associated plastic) is considered a credit card under Reg. Z if the account can be accessed by means other than a check or branch withdrawal. For example, if the line of credit can be accessed electronically through a means such as bill payment product. I've been told that this would make the product subject to all credit card rules rather than only the non-home secured credit line requirements. Is this correct? Can you refer me to where this appears in the Reg. Z?

Not to my knowledge, lblu.

It looks like under the section-by-section analysis the definition of credit card under 226.2(a)(15)does include lines of credit accessed solely by account number. That's quite a surprise to me. I guess I should have read more closely.

what's the definition of "soley by account number"...How many of those do you think there really are out there or would all of them be accessed by only the account number.

Let's see. I have a LOC and come into the bank. I want a cash advance at the teller line...I can give them my account number or my name...I don't have checks/plastic, but I can come in, or I can move it through internet banking or telephone transfer...what do they really mean by that?

All I can say is that when I read the definition it surprised the heck out of me. If the line of credit can be accessed online or by telephone transfers then we are considering it a credit card per opinion of counsel.

I do know that we had changes to our statements, but we didn't have changes to our account opening disclosures like we did with CC's. Did ya'll change anything to do with the initial disclosures?

Oh wait tho...we decided not to make any more LOC that weren't either HELOC's or overdraft protection...that's probably why we made the decision we did.

You'd think I'd remember more of the method behind the maddness, since I'm on the ground floor on these things...but once we decide to not bother with something, I tend to erase it from my already overfilled mind!

You link an unsecured LOC directly to bill-pay without it flowing through a checking account? Very unusual.