CUNA compiles FAQ on CARD Act queries

WASHINGTON (2/22/10)--As promised, the Credit Union National Association (CUNA) on Friday posted a list of frequently asked questions (FAQ) related to the Credit Card Accountability, Responsibility and Disclosure (CARD) Act of 2009, which becomes fully effective today.

The questions are culled from the many questions that were received after CUNA's recent audio conference calls, which took place on Feb. 2 and 11.

Following the conference call, attorneys in CUNA's regulatory affairs department attempted to answer more than 100 e-mailed queries. However, the answers provided below are solely the efforts of CUNA's compliance attorneys and have not been provided to the Fed for its interpretation.

Topics covered by the FAQ include questions on floor rates, change-in-terms notices, increases in variable rates, limitations on increasing annual percentage rates and fees, changes in credit terms, renewal or annual fees, business credit accounts, and expedited payments.

The FAQ also seeks to answer concerns on the central changes imposed by the CARD Act. They include regulations that prohibit rate increases in the first year that a credit card account is active, require co-signors for credit card accounts taken out by an individual under 21 years of age, require that creditors obtain the consent of the cardholder before charging over-the-limit fees, and limit many of the fees associated with so-called "subprime" credit cards.

CUNA will submit some of the questions to the Fed for its interpretation and will continue to update or add additional answers as they come up.

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