WASHINGTON (4/5/10)--While Regulation Z does not currently cover over the phone applications for credit cards, the Credit Union National Association (CUNA) has advised that credit unions that receive all necessary applicant information verbally, while still requiring the applicant to sign a text-version of their application at a later date, will “likely have satisfied the written application requirement” imposed on potential accountholders that are under 21 years of age. CUNA’s latest Compliance Challenge also addresses Regulation E. Responding to another query, CUNA says that in cases where members that have not opted in to the credit unions’ overdraft program but are abusing their debit cards by frequently overdrawing their accounts, the credit union can only suspend that members’ account “if it would do the same for members who have opted-in to the service.” Under Section 205.17(b)(3) of Regulation E , credit unions must “apply the same account terms, conditions, and features,” including interest rates, fees, and minimum balance requirements, “regardless of the consumer’s opt-in choice,” CUNA said. In another example, CUNA said that card issuers must provide 45 days of advance notice “when a discounted rate, such as a 25 basis point reduction in the credit card rate for payroll deduction, is increased to the normal rate.” This must be done whether or not the member still meets the requirements for the discount, according to CUNA. “However, a card issuer that does so cannot subsequently increase the rate unless permitted by one of the exceptions in Section 226.55(b), such as providing a 45-day advance notice of change in terms,” CUNA added. For more of CUNA’s Compliance Challenge, use the resource link.