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October 14, 2009

Comments

Joanne

So, all payments will be required to be "posted" same business day regardless of cut off time in an other provision of the act. If payment comes after cut off and FI is required by law to expedite (so it is credited the same day) we can charge a fee???? Am I missing something?

Southernmost Sue

Thank you so much for your hard work on getting the changes to the 21-day rule through the House. You rock!

Steve Van Beek

Joanne, I do not read the new changes as requiring the credit union to expedite payments. The changes to 226.10 will require credit unions to credit payments the date of receipt - but the staff commentary clarifies that the credit union does not need to post the payment on that date as long as the payment is accurately credited to the account as of the date of receipt. The commentary also indicates that the "date of receipt" is the date the creditor receives the payment.

That staff commentary and the text of 226.10 can be seen here: http://nafcucomplianceblog.typepad.com/sections/PaymentsGenerally.pdf

Lisa Lowe

Are we able to fee card holders Visa's when they are requesting a replacement cards, pin reissues, fed-x card to them, and statement copies?

Steve Van Beek

Lisa,
The restriction of 226.10(e) seeks to restrict the charging of a fee for accepting a payment unless it is expedited by a member service representative of the credit union.

This section would not prevent fees in other situations that are unrelated to accepting a payment from a member.

Lisa Lowe

Thanks Steve we just wanted to make sure we correct on this.

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