Card Act Requirements- Lines of credit

Posted By: M&M

Card Act Requirements- Lines of credit - 03/15/21 05:14 PM

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!
Posted By: rlcarey

Re: Card Act Requirements- Lines of credit - 03/15/21 05:45 PM

If there is no card then Subpart G of Regulation Z does not apply.
Posted By: M&M

Re: Card Act Requirements- Lines of credit - 03/15/21 05:49 PM

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...
Posted By: rlcarey

Re: Card Act Requirements- Lines of credit - 03/15/21 05:58 PM

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.