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Offering a VISA Debit Card to HELOC Customers

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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?

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 9/04/06

First published on 09/04/2006

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