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Consumer Law

: CL&P Blog

New Credit Card Regulations

By Jeff Sovern

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pOTS has now approved new credit card regulations.#0160; Their fact sheet includes the following summary of the regs:/p pspan style=FONT-FAMILY: Times New Roman1. /spanstrongspan style=FONT-FAMILY: Times New RomanInterest rate changes ? /span/strongspan style=font-family: Times New Roman;The rule (Section 535.24) requires savings associations to disclose at account opening the annual percentage rates (APRs) that will apply to the account and prohibits savings associations from increasing APRs unless expressly permitted. Savings associations are permitted to increase a rate at the expiration of a specified period, provided that the increasing rate was also disclosed at account opening. Once an account has been open for a year, a savings association may increase the rate for new transactions by providing a 45-day advance notice, as required by Regulation Z. Savings associations may also increase a variable rate due to the operation of an index. Finally, they may increase a rate on existing balances when the consumer is more than 30 days delinquent in paying the credit card bill. /span/p p style=TEXT-ALIGN: left2. strongspan style=FONT-FAMILY: Times New RomanReasonable time to pay ? /span/strongspan style=font-family: Times New Roman;The rule (Section 535.22) prohibits savings associations from treating a payment as late unless the consumer has been provided a reasonable amount of time to make the payment. As a ?safe harbor,? a reasonable time would be considered to be 21 days./span/p p style=TEXT-ALIGN: left3. strongspan style=FONT-FAMILY: Times New RomanPayment allocation ? /span/strongspan style=font-family: Times New Roman;When an account has balances with different APRs, the rule (Section 535.23) requires savings associations to allocate amounts paid in excess of the minimum payment using one of two specified methods: either allocating the excess payment to the highest interest balance, or proportionately to all balances./span/p p style=TEXT-ALIGN: left4. strongspan style=FONT-FAMILY: Times New RomanDouble-cycle billing ? /span/strongspan style=font-family: Times New Roman;The rule (Section 535.25) prohibits savings associations from using the practice sometimes referred to as two-cycle billing, when a savings association imposes finance charges based on balances associated with previous billing cycles./span/p p style=TEXT-ALIGN: left5. strongspan style=FONT-FAMILY: Times New RomanHigh-fee subprime cards ? /span/strongspan style=FONT-FAMILY: Times New RomanThe rule (Section 535.26) prohibits savings associations from charging fees for the issuance or availability of credit that consume /spanspan style=FONT-FAMILY: Times New Romanthe majority of the available credit during the first year after account opening. Fees exceeding 25 percent of the available credit must be spread over no less than the first six months that the account is open, rather than charged as a lump sum during the first billing cycle./span/p p style=TEXT-ALIGN: leftspan style=FONT-FAMILY: Times New RomanThe regs appear a href=http://http://files.ots.treas.gov/482007.pdfhere/a. /span/p p style=TEXT-ALIGN: leftspan style=FONT-FAMILY: Times New RomanUpdate: the Fed approved the regs; the relevant web page is a href=http://http://www.federalreserve.gov/newsevents/press/bcreg/20081218a.htmhere/a./span/p

Full post as published by CL&P Blog on December 18, 2008 (boomark / email).

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