Dissecting the Reg Z Proposal on Credit Cards
Posted by Steve Van Beek
Anthony did a great job yesterday with an introduction to the new proposed rules and how to handle the 841-pages of information. Â If you have begun reading through the proposal, you are aware of how difficult it is to focus on one particular issue. Â The Federal Reserve discusses a particular topic in the section-by-section analysis, then in the proposed rule itself as well as the proposed official staff commentary. Â The difficulty is that these discussions are spread throughout the 841 page proposal.
In order to help myself stay organized and focused on a particular issue - I've created separate documents that includes only the Federal Reserve's discussion on one topic.  For example, I created this 11-page PDF document which highlights the Federal Reserve's changes to 12 C.F.R. 226.9(e).  This document contains only the portions of the proposed rule that talks about the "Disclosures Upon Renewal of Credit Cards."
The document is composed of three separate parts:
- Pages 1-5 consist of the Fed's section-by-section discussion of their proposed changes to 226.9(e).
- Pages 6-7 contain the actual regulatory text of the proposed changes to 226.9(e).Â
- Pages 8-11 contain the official staff commentary to proposed 226.9(e).Â
For comparison purposes, the current language in 12 C.F.R. 226.9(e) can be found here. Â Additionally, here is our past blog posting on the changes to this 226.9(e) which were mandated by Section 203 of the Credit CARD Act.
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My thought is this approach will allow us to focus on specific topics in the proposed rule rather than being overwhelmed by the size and complexity of the rule as a whole. Â What are your thoughts? Â Is this a manageable way to work through the proposal? Â Leave a comment or shoot us an e-mail.Â
Here are two more examples:
Limitations on Fees Related to Method of Payment - 226.10 (e)
Changes by Card Issuer - 226.10(f) - (Discusses a Creditor Changing their Mailing Address)