Thread Options
#2250566 - 03/15/21 05:14 PM Card Act Requirements- Lines of credit
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 527
Midwest
It's been a long time since I've looked in detail at the Card Act. The pertinent provisions of the regulation speak frequently to "Issuer" and "credit card account". But, do unsecured, open-end lines of credit, used for overdraft or other purposes, need to follow all of the same requirements? I'm particularly looking at online applications, and how/where to present the disclosures during the application process, and whether the ability to repay requirements, including those for young consumers, also apply to these non-credit card products. TIA!

Return to Top
Lending Compliance
#2250569 - 03/15/21 05:45 PM Re: Card Act Requirements- Lines of credit M&M
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 76,928
Galveston, TX
If there is no card then Subpart G of Regulation Z does not apply.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2250570 - 03/15/21 05:49 PM Re: Card Act Requirements- Lines of credit M&M
M&M Offline
Platinum Poster
Joined: Nov 2003
Posts: 527
Midwest
Thanks, Randy. That's what I thought, but it threw me since Subpart G says "Credit Card Accounts and Open-End Credit Offered to College Students". It seems like it makes it broader than credit cards...
Last edited by M&M; 03/15/21 05:52 PM.
Return to Top
#2250573 - 03/15/21 05:58 PM Re: Card Act Requirements- Lines of credit M&M
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 76,928
Galveston, TX
Official Interpretation
57(a) Definitions
57(a)(1) College student credit card
1. Definition. The definition of college student credit card excludes home-equity lines of credit accessed by credit cards and overdraft lines of credit accessed by debit cards.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z