Credit Card Act Confusion

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Question:

We are totally confused on the subject of the recent Credit Card Act. We are understanding that the TILA amendments apply also to our HEQ Lines of credit. We now mail statements at month end with a due date ten days from the statement drop and allow fifteen extra days to make payment without a late fee or any reporting to a credit bureau. Are we in compliance or must we make our payment due date twenty-one days or more for mailing purposes, and then, by contract with the customer, still allow the grace period?

Answer:

If you charge a late fee, you have to mail/deliver the periodic statement twenty-one days before the legal due date for the payment. You cannot count the fifteen day grace period within the twenty-one day period.

First published on BankersOnline.com 10/19/09