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January 10, 2012


Darla Grimes

Since this is not a substantive change, will this require a 45 day change in terms notice?

Steve Van Beek

Based on the language of Regulation Z - the change from the Fed's contact information to the CFPB's contact information is considered a "significant change in account terms." This is because the website information is required under 12 CFR 1026.6(b)(2)(xiv). Since the website information is covered by 1026.6(b)(2) - the 45-day change-in-terms notice is triggered (as is the right to reject). This is despite the fact that the change was mandated by Dodd-Frank and the regulators and not a change the credit union made. This is clearly one of those unintended consequences that seem to pop up more and more as the regulations become more complex.

JC Campos

I understand that a change in the terms listed under 12 CFR 1026.6(b)(2) is a "significant change", but are we really "changing" any account terms for existing credit card customers? The CFPB website is not part of our account agreement with our customer, and does not affect their account with us. In other words, we are not changing that term for existing customers. The existing customers can continue to look to the FRB for this information. We are only required to disclose this new website information when a new account is opened, and only after January 1, 2013.

Steve Van Beek

We have a blog post scheduled for Tuesday, October 23rd which will look at the details and confusion related to this change-in-terms issue. Stay tuned.

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