Written by Michael Coleman, Regulatory Compliance Counsel
The end of 2012 is fast approaching, and so are compliance deadlines (although if you are reading this we have successfully avoided the end of the world according to the “interpretation” of the Mayan calendar, so we have that going for us). Yesterday we blogged about required updates for adverse action notices and risk based pricing notices. Today we would like to focus on credit cards updates required by January 1, 2013.
Regulation Z - Credit Card Application & Account Opening Disclosures
When the CFPB republished Regulation Z, Sections 12 CFR 1026.60 (applications and solicitations) and 12 CFR 1026.6 (account opening disclosures) were changed to reflect the CFPB's authority over Regulation Z and credit cards.
After January 1, 2013, your credit card disclosures would need to reference the CFPB (in the past they mentioned the Federal Reserve). You can see the small change by viewing the Fed's prior G-10(B) model form with the CFPB's current G-10(B) model form.
Here is the language from the application and solicitations disclosure regulation - 12 CFR 1026.60(b)(15):
"(15) Web site reference. A reference to the Web site established by the Bureau and a statement that consumers may obtain on the Web site information about shopping for and using credit cards. Until January 1, 2013, issuers may substitute for this reference a reference to the Web site established by the Board of Governors of the Federal Reserve System."
Similar language is included in 12 CFR 1026.6(b)(2)(xiv) for account opening disclosures.
Note: This disclosure is only required for credit card accounts. Thus, the change would only need to be made on your credit card application and solicitation disclosures and your credit card account opening disclosures.
Additional details and discussion available in this January 10, 2012 blog post.
NAFCU’s Offices Closed for the Holidays – Just a reminder that NAFCU’s offices will be closed all next week and through the beginning of the new year. The blog will also be on hiatus during this period. NAFCU’s offices will re-open on Wednesday January 2, 2013, and we will be back to blogging as well to start off the new year. From all of us here at NAFCU, we wish you and yours a safe, happy, and hopefully restful holiday season!