This afternoon, CUNA President Dan Mica sent out a nationwide plea for credit unions to express their concerns to the Federal Reserve concerning costs and regulatory burdens their credit union faces in complying with the 21-day rule and other aspects of the Credit Card Accountability and Disclosure Act of 2009. For more background, read CUNA’s Regulatory Comment Call on the interim final rule. Comments are due to the Fed by September 21, but compliance begins on August 20.
The CARD Act's 21-day rule poses a particular problem for credit unions since it applies to open-end lending plans, common among credit unions but not so much in banking. Originally, the CARD Act dealt with credit card consumer protection issues but, for whatever reason, language dealing with other open-end credit was added quickly by legislators at the last minute in a closed door process.
All open-end lending credit unions are encourage to send a comment letter to the Federal Reserve as soon as possible. The easiest way is by e-mail to regs.comments@federalreserve.gov Please send a copy to CUNA at nclyburn@cuna.com
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