Answer:
1. You don't need to raise your club age to 62 unless you charge a lower fee for overdrafts for club accounts or set a higher ODP limit for club accounts. Under those circumstances, an age limit of 50 would be a violation of Reg B. [Editor's Note: Recent rumblings from some of the regulatory agencies, however, indicate that some are taking the position that if the club account has an ODP feature (which would be considered a type of credit) and any feature of the account is more or less favorable than that offered to those under the age for qualification (which you've set at 50), you have a potential Reg B age discrimination problem, even if the terms of the ODP part of the account are the same for these customers as for others.]
2. Reg Z will affect the repayment plan if it is payable by written agreement and either payable in more than 4 installments or subject to a finance charge. So you can avoid Reg Z disclosures in your repayment plan by either not having a written agreement, or by insuring that it is payable in 4 or less installments and not charged a finance charge. Or you could just go ahead and make sure your notes for your repayment plan encompass Reg Z disclosures.
First published on BankersOnline.com 08/01/05
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