We are confused. I thought there was some clarification that the 21 day lead time DOES apply to open credits, such as HELOCs along with, of course, credit cards. Please confirm. I remember there was some kind of small print that everyone was focusing on,...

The Credit Card Technical Corrections Act of 2009 was passed by Congress and signed by the President on 11/6/09.

Originally under the Credit Card Act , for open end consumer credit, creditors had to send a billing notice 21 days in advance of the payment due date. This provision, which was effective on August 20th included credit cards, HELOCS and overdraft lines of credit.

The Cr Card Tech Corrections Act revised this provision and limits the application of the 21 day rule to credit cards only.

Take a look at Reg Z Section 226.5(b) if you need a regulatory citation.

Hmmmm. I found the Q&A dated Feb. 8, 2010 from a BOL webinar from 2010 'The Non-Credit Card Provisions of the Fed's Credit Card Act Final Rule." , by Carl Pry. Question 24 talks about HELOCs. On the page following, at the top, Carl listed a short summary of the provisions that apply to HELOCs. He referenced 226.5(b)(2)(ii)(B) that, effective, there is a 21 day lead time.

So, 21 day rule applies, right?????

::points up::

What Ahou said.

It applied then was rescinded a few months later. IN the meantime, we had already changed all of our statement drop dates so we left them that way.

Ditto here. Changed the dates and now we have to live with them.

We're leaning that way but we built apx. 24 days into the bill drop date to make sure customer got the 21 day lead time. We want to reduce this to 18-21 day. the customer will still get more time than in the past but we won't always be giving the full 21 days. We thought as long as it wasn't a rule we can do this....if you think otherwise, please let me know.