Does the Reg Z CARD Act apply to debit cards that can access a personal line of credit indirectly (via a DDA)?

No. If you search for "debit card" throughout the supplemental information, regulation, and commentary of Regulation Z in implementing the Card Act - you'll see they are specifically excluded. Debit cards are generally covered by Regulation E.

You don't have to look too far.

226.2 (15)(i) Credit card means any card, plate, or other single credit device that may be used from time to time to obtain credit.
(ii) Credit card account under an open-end (not home-secured) consumer credit plan means any open-end credit account that is accessed by a credit card, except:
(A) A home-equity plan subject to the requirements of § 226.5b that is accessed by a credit card; or
(B) An overdraft line of credit accessed by a debit card or an account number.

If we do not offer credit card access on our Home Equity Lines of Credit, then the new provisions effective 10/1/11 do not apply, correct?

Not entirely true. If you offer open end non home secured credit plans there are a few changes with the 10/1 rules.

Whoops. I should have worded better. My primary responsibility is just real-estate secured lending compliance. The other guys cover everything else. : )

I wanted to confirm that the provisions are not applicable to home secured open end products.

I would also like to know the answer to this. And what are the requirements exactly for HELOC's that can be accessed through a debit card?

bump