Posted by Anthony Demangone
Earlier today, President Obama signed H.R. 3606 into law, which provides a technical fix for the 21-day issue by limiting its affects to credit card accounts. Let me know when you're done clapping.
OK. Here's what that did. With a stroke of the pen, the Truth in Lending Act has been amended. The Fed will need to update regs and guidance to implement this, and we can expect that information when the Fed issues the final rule to implement the portions of the Credit CARD Act due to go into affect on February 22, 2010. Those rules should come by year's end. But no matter how long the Fed takes, the law was changed the moment President Obama's signature graced the document.
I cannot say with 100 percent certainty how the Fed will address this issue. There always is a bit of haziness until you see what the final regs say. Can credit unions that moved due dates simply move them back without some sort of notice? I wouldn't think so. But again, we'll have to wait for the final rule to know what the Fed really thinks about all of this. In any event, this sure is wonderful news.
And with the news, it signals the end of one of the strangest chapters in my life as a compliance professional.
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