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Thursday, September 3, 2009

Credit Card Act Compliance. A Little Break. Maybe.

The Credit Card, Accountability, Responsibility, and Disclosure Act of 2009. I get it! the C.A.R.D. Act . . . those wacky congress folks are so darn clever with the names of their regs.

Under the CARD Act, credit unions are required to deliver periodic statements for open-end consumer credit plans at least 21 days before the payment due date, this portion of the Act is effective August 20, 2009. According to a recent NCUA Release, "the Federal Reserve Board acknowledged that some creditors may experience difficulties, for open-end credit plans other than credit cards, with revising their billing systems by August 20", and "that for a “short period of time” a creditor “may remedy this technical issue by prominently disclosing elsewhere on or with the periodic statement that the consumer’s payment will not be treated as late for any purpose if received within 21 days after the statement was mailed or delivered.”

The NCUA will review credit unions on a case-by-case basis to determine if reasonable efforts have been taken to come into compliance with the CARD Act. In any case, no late fees should be imposed under these circumstances.

Speaking of credit cards, my card was stolen a few weeks ago. I told the credit union to just let the thief keep it . . . he spends a LOT less than my wife. Ba-dum-dump!

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