We are terminating an inherited credit card portfolio - the only reason for the termination is we don't want to offer a credit card product. We are sending a change in terms notice to the customer in the form of a letter to say the cc plan is being terminated and we are lowering your interest rate - all other account terms will remain the same. We are allowing the customers to pay off the remaining balance under the original terms - except for the lower rate.
Q. Since we have terminated the plan would we still need to comply with some of the Credit card act rules effective 2/22/10
Q. Since we have effectively converted an open-end plan to a closed-end plan, would redisclosure be required under Reg Z comment 17(b)2 or would the customer letter we are sending be sufficient disclosure since only the rate is changing?

Thanks

Expedition, Did you get an answer? I have a similar situation.