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CUNA sets July 28 audio call on CARD Act notice provision
WASHINGTON (7/20/09)—On July 28 at 1:30 p.m. (ET), the Credit Union National Association (CUNA) will hook up interested credit union representatives with financial industry experts who will address concerns about a 21-day notice period under the Credit Card Accountability, Responsibility and Disclosure (CARD) Act. CUNA has been working with the Federal Reserve Board to convey credit union concerns regarding a specific requirement in Section 106 of the CARD Act. That provision prohibits creditors from claiming a payment is late unless that creditor adopts reasonable procedures to ensure that periodic statements are delivered to consumers no later than 21 days before the payment due date. Last Wednesday, the Fed issued interim final rules to implement that and other CARD Act requirements. On next Tuesday’s 90-minute audio call, Fed Senior Attorney Benjamin Olsen and University of Wisconsin CU Chief Credit Officer Mike Long will be among the speakers available to outline the Fed plan and address credit union concerns. Long also chair's the CUNA Lending Council Regulatory Committee. At issue is the fast-approaching Aug. 20 compliance date for the notice provision, which stretches well beyond credit cards to also cover such things as: general lines of credit, lines of credit associated with share draft and checking accounts, signature loans, and home equity lines of credit and--of particular concern to credit unions--to multi-featured, open-end lending programs. CUNA has urged an extended compliance timeframe. Notably, when the Fed issued its interim rule, the agency indicated that "for a short period of time after August 20," periodic statements for open-end credit other than credit cards may disclose due dates that are inconsistent with the 21-day requirement under certain circumstances. However, the Fed has to date declined to define the ambiguous “short period of time.” Other experts on hand for the call include CUNA Senior Assistant General Counsel Jeff Bloch and CUNA Assistant General Counsel and Senior Compliance Counsel Mike McLain. Use the resource link below to register for this important session.
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