Effective Dates May Move Up. CARD Act Update.

I'm always hesitant to report proposed legislation because sometimes the text of one bill is often voted down, incorporated into another bill, changed, or regurgitated as something entirely different. However, this one seems to have a high likelihood of passing in some form, so you might want to "gear up". Side note: isn't "regurgitated a perfect word when describing new legislation?

On October 22nd, 2009, th House Financial Services Committee approved H.R. 3639 (read it here), which would move up the remaining effective dates of the Credit CARD Act from February 2010 to December 2009. However, two key amendments were added to the bill that will effectively exempt credit unions from these earlier compliance dates.

The first amendment limits the earlier effective dates for all of the provisions of the bill to issuers with more than 2 million cards in circulation. This effectively exempts all credit unions. Gift card provisions were not changed.

According to Dave Adams, Michigan Credit Union League CEO, the legislation pushing up the effective dates is a separate issue from the fix we’ve been seeking in the Credit CARD Act to narrow the scope of the 21-day periodic notice requirement from all open-end credit to only credit cards.