Compliance Blog

Yesterday, the Federal Reserve released the long-awaited final regulations that amend its open-end lending rules.  Here's what happened. 

• First, the Fed issued a final rule to withdraw Regulation AA (UDAP.)  The UDAP rule was overtaken by the Credit CARD Act, so the Fed withdrew it as "unnecessary."  The Fed explained that the UDAP requirements have been revised for consistency with the Credit CARD Act and have been incorporated in the new rule, linked above.  I expect that NCUA will withdraw its UDAP rule as well.
• Second,  the Fed issued another final rule to withdraw the Regulation Z final rule that they issued back on January 29, 2009.   This was the rule that had the original July 1, 2010 effective date.  The Fed has indicated that those requirements have been revised to be consistent with the Credit CARD Act, and those requirements have been incorporated within the massive Reg Z final rule.   How are they handling the two different compliance dates?

The new final rule is effective on February 22, 2010. However, to the extent consistent with the Credit Card Act, the Board has retained the July 1, 2010 mandatory compliance date for many of the provisions incorporated from the January 2009 Regulation Z Rule. The Board has provided additional discussion of the withdrawal of the January 2009 Regulation Z Rule and the mandatory compliance dates in the Supplementary Information for the new final rule.(Emphasis added.)

And the Fed also issued the massive, 1,155 page final rule to amend its open-end rules.  As noted above, it massages and incorporates the UDAP and original Reg Z open end rules. Here's a link to that 1,155 page document. 

Here's some useful links that we've created:

1. Save a copy of this final rule to your computer so that you don't have to hunt down the Fed's website every time you want to review it. 
2. Read the 12-page summary of major revisions.   
3. Do you just want to look at the regulations?  Here's a link to the regulatory language.  Granted, it is still 144 pages long.  But I added section bookmarks to help you navigate it.   
4. What rules apply to just credit cards?  Which rules apply to all open-end lending?  Look at this chart.
5. What are the mandatory compliance dates?  The Fed lays this out in excruciating, yet necessary detail, in these 37 pages.   

That should be enough to get you guys rolling.  Don't worry - we're not done on this issue.  Not by a long-shot.