21 day fix

From CUNA News Now 11/10/09:

WASHINGTON (11/10/09)--Even before President Barack Obama signed the CARD Act Technical Corrections Act (H.R. 3606) into law on Friday, staff from the Federal Reserve had confirmed with the Credit Union National Association that Fed staff will include this change in the CARD Act final rule that will be issued by the end of the year, or January at the latest.

These rules will address the provisions that were effective as of Aug. 20 and that will be effective as of Feb. 22, 2010.

Fed attorney Ben Olson also indicated that the Fed staff has no objection to the correction, telling CUNA Senior Assistant General Counsel Jeff Bloch that the correction "makes a lot of sense."

The CARD Act change fixes portions of the act that implied that a 21-day late notice requirement applied to all open-end credit by clearly stating that late-notice provisions apply to credit cards only.

CUNA consistently argued that lawmakers had always intended to apply the provision to credit cards only, and worked closely with lawmakers and their staffs to inform them that the CARD Act drafting error prevented credit unions from granting biweekly payment plans or sending consolidated billing statements to their members and would force them to change payment due dates for members that had previously chosen due dates based on their specific financial circumstance.

CUNA President/CEO Dan Mica hailed the quick and decisive work by the House, Senate, and President, saying that the to-be-enacted legislation "gives credit unions the opportunity to go back to doing what they do best: Serving their members with affordable and needed financial services."

Use the resource link below for comprehensive compliance information about "un-complying" with the 21-day requirement now that the fix has been enacted.