CUNA doc helps CUs cope with CARD Act regs

WASHINGTON (8/6/09)—The Credit Union National Association (CUNA) is working for legislative or regulatory relief for the by-now-well-known 21-day notice provisions for open-end credit plans, other than credit cards set, set to take effect Aug. 20. Meanwhile, however, CUNA has created a compendium of information to help credit unions tackle the "horrendous" compliance challenges that loom ahead.

As a cure, CUNA is seeking a law change so the notice provision would apply only to credit cards. Concurrently, CUNA is addressing the problem via a regulatory route urging the Federal Reserve Board to approve a compliance date delay.

The Fed rule implements provisions of the Credit Card Accountability Responsibility and Disclosure Act of 2009.

In the memo, CUNA details steps that credit unions must take to comply with the 21-day requirement and the 45-day change-in-terms requirement. CUNA provides an overview of these regulatory requirements, provides information on some of the alternative approaches that credit unions are considering, and addresses some of the more frequent questions that have been asked about the regulations.

While CUNA does not specifically advocate or suggest any method of complying with the 21-day requirement, the memo does present a number of options that have been taken by some credit unions, including changing due dates to establish a uniform payment due date, printing the current and following month's payment due dates on the account user's periodic statement, and retaining the existing due dates, but providing additional periodic statements.

CUNA has also provided answers to which types of loans are covered by the 21-day requirement, how the 21-day period is determined, and which actions a credit union could take to assure delivery when a member has decided to use electronic periodic statements.

For access to the document, use the resource link.

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Resource Links
CUNA compliance guide
Credit Cards: Switch and Save statement stuffer
Credit Cards: Switch and Save drive-up envelope


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