Compliance Blog

As we prepare for the new requirements brought on by the Credit CARD Act of 2009, I wanted to remind credit unions to be sure to review the Federal Reserve's proposed rules to implement the requirements.  The Federal Reserve's proposal takes the new requirements and expands upon them and details the steps credit unions will need to take to comply. 

NAFCU prepared an "Overview of the Credit CARD Act" and put it on our compliance homepage.  This overview was drafted as a summary document to inform credit unions about the new requirements.  NAFCU will not be able to continue updating the overview as the requirements get implemented by the Federal Reserve.  It could still serve as a useful overview, however, as we move toward complying with the new requirements - be sure to look to the proposed rules for the details.  Here is a blog post that breaks the proposal into 25 topics to analyze.  

In short, the Credit CARD Act adds new requirements for credit unions - but the Federal Reserve's amendments to Regulation Z implement the new requirements and provide details and specifics that credit unions need in order to be in compliance.  Further, when the Federal Reserve finalizes its amendments - be sure to work off the final rules as they may have changed during the regulatory process from the proposed rules.

For an example, the Credit CARD Act did not appear to limit the minimum payment warning to credit card accounts.  However, the Federal Reserve used its authority to interpret the Truth in Lending Act (which the Credit CARD Act amended) to limit the repayment warnings to credit card accounts [at least in the proposal - we are waiting for the final version to confirm].  Anthony did a great job of explaining this in this blog post.