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October 06, 2009


Cheryl Hart

Can you tell me the actual difference between this and the CCA? Come on... are they really different?

Michele Boven

I'm confused. Is the Federal Reserve Board now making proposed changes to the Credit Credit Act? If so, if I am interpreting correctly, it appears their proposals are already in the Credit Card Act, such as section 171 (increasing APR's, etc). Please clarify....

Anthony Demangone

The Credit CARD Act made into law to do a number of things. The major goal was to amend the Truth in Lending Act to provide a number of consumer rights in the lending arena. But the Truth in Lending Act allows the Fed to issue regulations in a way that, while maybe not 100 percent in line with the Act, still achieves the Act's goal. Case in point, the Act appears to require payment warnings for ALL open end credit. The Fed's proposal would limit that requirement to credit card accounts. So, you have to review this proposal (and the future final rule) closely, as it may deviate a bit from the Credit CARD Act/Truth in Lending Act.

Angela Baker

Official staff comment (2)(a)(4) says that "the sending of a regular payment reminder (rather than a late payment notice) establishes a cycle for which the creditor must send periodic statements." What effect does sending payment reminders have on the timing of sending the periodic statement?

Anthony Demangone

It looks like they are saying that if you send a monthly payment reminder, you establish a monthly cycle. There's no other guidance on that issue, so I'm not 100 percent sure. But that is my initial read.

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