Answer:
The error resolution notice is required for all openend credit. You can omit any nonapplicable portions of the model language.
First published on BankersOnline.com 3/17/03
Reg Z, Billing Error Resolution, and Initial Disclosures
Question:
Regulation Z section 226.13 refers to a consumer's credit card or openend credit plan. The commentary makes it sound like the billingerror resolution notice is required for any openend plan but the notice set forth in Appendix G keeps referring to a credit card. Do we need to include the billing error resolution in the initial disclosure and an annual notice for a line of credit where there is no access card? If so, do we just delete the references to the access card and the $50 limit?
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