Reg Z Proposal to Implement the Credit CARD Act - 25 Sections To Analyze
Posted by Steve Van Beek
Last Thursday, I asked the readers if our approach to handling the massive Reg Z proposal to implement the Credit CARD Act provisions was manageable and if we should continue. Â The answer was a resounding: Yes, please! Â Starting tomorrow, we will begin analyzing these sections, one-by-one.Â
Below you will find 25 sections that we have "ripped out" of the Reg Z proposal and placed in separate PDF documents organized by topics.  These individual PDFs contain the preamble (i.e. section-by-section analysis), proposed regulatory text, and the proposed official staff commentary to each particular section.  We have also added a cool strike through feature - which should help clarify which information in each individual PDFs we will be focusing on. Â
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Tip: Try to take a risk-based approach to these sections. Â For example, if your credit union does not offer credit cards with annual fees, leave that section for later (same with sections like double-cycle billing) - and focus on the sections that will definitely impact your credit union (i.e. repayment disclosures, payment allocation, increasing APRs on existing balances, etc.). Â
Main Changes to Reg Z to Implement the Credit CARD Act Provisions
Increasing APRs on Existing Balances
Bonus: Model Forms from Appendix G (large document - useful to get a visual of some of the changes).  Â