The Non-Credit Card Provisions of the Fed's Credit CARD Act


Presented by: Carl Pry

Add CD-ROM to Cart:

(Product will be shipped via USPS)


Don't let the name fool you - there are significant parts of the rule that cover non-credit card open-ended plans.

On January 12th, the Federal Reserve issued a 1,155 page final rule implementing new provisions affecting open-end credit plans under Reg. Z. The main purpose of the final rule is to implement Stage 2 of the Credit CARD Act, passed last year. These rules affect mostly credit card accounts, of course, but there are several provisions in the new rule that affect non-credit card open-ended accounts.

But that's only the beginning of the confusion, unfortunately. A quick read of the preamble states that this final rule withdraws a final rule issued by the Fed in January of 2009. The new rule is a combination (to lessen confusion, according to the Fed) of last year's final rule and the rules mandated by the Credit CARD Act. In addition, there are two separate effective dates: February 22nd, and July 1st, 2010.

What does all this mean? Most importantly, there are provisions that affect open-ended plans that aren't credit cards. Even if your institution doesn't offer credit cards, this rule will apply if you offer other consumer-purpose open-ended credit plans (such as HELOCs or signature lines of credit).

We'll discuss just those provisions that affect non-credit card plans. If you don't offer credit cards, this is the session for you. How will all these changes affect your institution? What is effective when? We'll lay the changes out in an easy-to-understand format, so you'll know exactly what the changes are and when they're going to happen.

In this webinar, we'll address the details of the final rule, including:
  • Showing exactly what provisions are effective and when
  • What provisions apply to all open-ended plans, which apply to just credit cards, and everything in between
  • The difficulties in making certain disclosure requirements effective in February, but the formatting isn't required until July
  • New requirements for advertising
  • Restrictions on "prohibited inducements": make sure your marketing department knows these
  • New change-in-terms requirements
  • Penalty or delinquency rate increase provisions
  • What to expect in the future, as the Fed isn't done yet
This will be an interactive session with several opportunities for questions and answers, so come prepared to discuss your needs and issues.

Target Audience
Anyone involved in open-ended credit operations, promotion, servicing, and compliance will benefit from this session, including compliance officers, marketers, senior management, IT personnel, bank counsel, operations, and privacy, among others.

The Speaker: Carl Pry, J.D., is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Vice President and Compliance Manager for a large financial institution in Ohio. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at dozens of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.

(requires Windows Media Player and IE).

CD-ROM Includes:
  • Complete presentation (including slides and audio)
  • Written Materials
  • Follow-up Q & A
You have the right under this license agreement for this CD-ROM to use this presentation on a single-workstation. Use on a network is in violation of the copyright agreements. CD may be used by multiple users at a given institution but may not be placed on a network or in any other multi-user environment.

This program was recorded in its entirety in February 2010. The CD-ROM includes program slides, materials (if available) and follow-up Q & A document.

Add to Cart:

  • Model: cd_openend0210
  • Manufactured by: Glia Group, Inc.

This product was added to our catalog on Tuesday 26 January, 2010.

Copyright © 2022