CUNA Mutual's Loanliner Compliance experts advise that the new year brings with it an increase in Regulation Z’s safe harbor threshold for credit card penalty fees. Effective January 1, 2019, the threshold amounts will increase $1.00 to:
- $28.00 for the first violation
- $39.00 for a violation of the same type that occurs within the next six billing cycles
As a result, credit unions will have the option to increase their penalty fees. When considering this option, review any change in terms notice requirements pursuant to Regulation Z §1026.9 for existing cardholders. Loanliner credit unions can
submit questions online or call 800.356.5012. Additional information and resources are available in the
Lending Resource Center (User ID and Password required).
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