Change-in-terms Notice Deadline Approaching for Credit Card Disclosures

As credit unions are well aware, the authority for Regulation Z has been transferred to the Consumer Financial Protection Bureau (CFPB). Effective Jan. 1, 2013, the CFPB’s website must be listed in the Credit Card Account Opening disclosure per 1026.60(b)(2)(xiv).

While the CFPB verbally told the Credit Union National Association (CUNA) that this was a minor change, credit unions need to be aware that any change to a required disclosure element triggers the requirement for credit unions to provide a 45-day change-in-terms notice per 1026.9(c)(2). Credit unions need to decide if they wish to follow a verbal non-binding response or eliminate the risk of ligation by providing the update to their members.

In order to meet the 45-day advance-notice-of-change deadline, credit unions will need to send out the notice no later than mid-November. Per Regulation Z, credit unions may choose to include the change in terms on or with the members’ statements, or provide it on a notice separate from the periodic statement.

If the notice is included on or with the periodic statement it must follow the format requirements provided by 1026.9(c)(2)(iv)(D).

 

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Around the NW, Compliance.