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Offering a VISA Debit Card to HELOC Customers

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Question: 
Marketing is considering mailing new VISA debit cards to existing HELOC customers. I know this product is governed under Reg Z. What disclosures must accompany the mailing?
Answer: 

You are going to have to follow the guidance found at 12 CFR 226.9(b) that addresses the requirements for the issuance of a supplemental access device to an open-end credit plan. I would also recommend that you call your VISA representative as the issuance of a VISA debit card to access your HE line of credit may violate your agreement. Last I heard VISA does not allow you to issue their debit cards when in fact they would be considered credit cards.

First published on BankersOnline.com 9/04/06

First published on 09/04/2006

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