Compliance Blog

Posted by Anthony Demangone

We've heard from quite a few credit unions that plan to "migrate" due dates to later dates in order to comply with the Rubik's Cube regulation the 21-day "issue."  Here are just some thought for credit unions that are walking down that path.

• Remember that a different provision of the Credit CARD Act requires due dates for credit cards to be on the same day each month.  Steve wrote about that issue back on July 2.  This requirement kicks in on February 22, 2010.  While there's some confusion as to what the "same day each month" means, we expect the Fed to clarify its meaning when it issues a proposed rule to implement that Credit CARD Act provision.  So, while the same day issue only applies to credit cards, we understand that many credit unions are pushing all open dates back.  It may make sense to choose a single day to ease compliance burdens or simplify things.

• What did you do yesterday for your open end loans?  While I'm sure many of you already have thought about this, I wanted to mention it anyway.  If you are planning to migrate due dates to a later date (i.e., the 28th of each month), have you already built that into your procedures?  Allowing members to choose an early due date just doesn't make sense if you are going to migrate them to a later date next month.

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NCUA has decided to extend the 18 percent usury ceiling for another 18 months, beginning September 10, 2009.   I'm no good at date-related math (or really any math, for that matter), but I think this means we're good through early March 2011.  Read all about it here.

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These photos of Kate sum up my thoughts about this 21-day issue.

First, it surprised us.

 

The more we read, the more confused we became.

It was so overwhelming, we just looked punch-drunk.

 

And then reality set in.

Have a great weekend, everyone!