Responding to the Credit CARD Act / Reg. Z

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Updated: July 20th 2010

This page is where we'll post communications related to the Credit Card Accountability, Responsibility, and Disclosure (CARD) Act and its affect on credit unions using CU*BASE. This is not intended to be an interpretation or explanation of the Act itself, but rather a discussion of various tools and services CU*Answers can offer to help credit unions as they work to comply with these new and evolving regulations.

Request a Flood of Contract # and Date for MFOEL Plans

Complete this form to request CU*Answers to flood a Contract # and Date for members with loans under a Multi-Featured Open-End Lending (MFOEL) Plan. The form must be received by Thursday, July 15, 2010.

Submit the completed form to CU*Answers Client Services at csr@cuanswers.com or via fax to 616-285-7285.

Discussions about Multi-Featured Open-End Lending (MFOEL) Plans

We are working on a plan to modify CU*BASE and our member statements to allow for new information about your MFOEL plans to be disclosed to members. Remember that this is just part of the story: your CU can already update plan information on the CU*BASE Open-end Loan Contract screen. And you should start making plans to flag the sub-accounts covered by the plan once we get the software changes in this summer. Is your paperwork in order? Will you be ready to mark the accounts that will need the new disclosures?

Revised MFOEL Enhancements Project Plan (working project specifications, including targeted completion deadlines)
Revised Mockup of Statement Changes for MFOEL Plan Disclosures (an excerpt from the project plan)
MFOEL Email from Randy Karnes (sent 4/15/10 to the CU*Answers and Xtend Boards)
Reg. Z and the Impact on MFOEL Plans (Audit Link Advisor Issue 10, sent 4/12/10)

What about updated forms?

Status report as of April 30, 2010: We have received updated forms from CUNA Mutual with the required Reg. Z changes. All other forms providers have passed our deadline date of April 23 (as published in the recent edition of the Audit Link Advisor). Therefore, the new Reg. Z-compliant forms may not be ready by July 1, 2010 (which is the Reg. effective date). If you have not heard from your forms provider and are currently using the MFOEL plan, please contact them directly.

Below is a list of forms we received from CUNA. The Form ID can be found at the bottom right hand corner.

BXX017 - OE Application & Plan Signatures w/CC - CU Copy - Simplified
BXX028 - OE Plan Signatures - CU Copy - Flexible
BXX038 - Credit Agreement - Borrowers Copy - Flexible/Simplified
BXX049 - Credit/Security Agreement PLUS - Borrowers Copy - Flexible/Simplified
BXX079 - OE Plan Signatures PLUS - CU copy - Flexible
VXFL75 - FL Sec w/o-Debt w/Sig w/o-Ins
VXWI08 - WI Sec w/o Debt w/Sig w/Ins
VXX003 - STD Loc w/o-Debt w/Sig w/o-Ins
VXX038 - STD Sec w/o-Debt w/Sig w/o-Ins
VXX059 - STD Sec w/o-Debt w/Sig w/Ins
VXX07D - STD Sec w/o-Debt w/Sig w/Ins
VXX088 - STD Dbr w/o-Debt w/o-Sig w/o-Ins
VXX098 - STD Dbr w/o-Debt w/Sig w/Ins

Communications from CU*Answers

Credit Card Penalty Fee Changes Coming August 22 (announcement sent July 19, 2010)
Credit CARD Act - More Statement Changes Coming for March 2010 Statements
- Read the Summary of Statement Changes
- View the Statement Samples
Recommendations for the Credit CARD Act (Audit Link Advisor Issue 09, sent 3/3/10)
Watch the recorded Webinar "Learning Together About the Credit CARD Act" hosted by Jim Vilker, Audit Link Manager; Geoff Johnson, VP Lending Products; Jody Karnes, CIO; and Dawn Moore, VP Writing Team/Product Design. Topics included reviewing the recent communications about the Credit CARD Act and answering client questions.
Handling Delinquent Loans After Adjustment Due Dates
Credit CARD Act – Preview of Statement Changes (email sent February 22, 2010)
- Read the Summary of Statement Changes
- View the Statement Samples
Credit CARD Act Update: Preparing for The Feb. 22 Deadlines (announcement sent January 29, 2010)
Responding to the Credit CARD Act (announcement sent July 23, 2009)
A letter to CU*Answers clients from our statement processor, Sage Direct
An analysis worksheet developed by Sage Direct showing a history of mailing dates for member statements over the past year
Statement Processing: Complying with Reg Z and the Credit CARD Act (a note about statements for CU CEOs/Managers from the desk of Randy Karnes, sent 9/22/09)

Request a Flood of Due Dates

Complete this form (UPDATED 8/6/2009) to request CU*Answers to adjust your loan account due dates for affected loan categories and/or online credit cards. (NOTE: This is a Microsoft Word document that can be filled in electronically.)

Submit the completed form to CU*Answers Client Services via email to csr@cuanswers.com or via fax to 616-285-5735.

Answers to Frequently-Asked Questions

Search the special Credit CARD Act section in the AnswerBook

Learn More about the Credit CARD Act

Here are a few resources we have found helpful:

Final ruling published by the Federal Reserve (12 CFR Part 226

CUNA CARD Compliance Memo dated 8/5/09

CUNA - http://www.cunamutual.com/portal/server.pt?open=514&objID=383317&mode=2&cached=true#var=cross

NAFCU - http://nafcucomplianceblog.typepad.com/nafcu_weblog/ (this is a subscribers-only service)

Add Your Voice

Let's learn together! Send contributions to dmoore@cuanswers.com and we'll post them on this page. Other questions should be directed to any Client Service Representative csr@cuanswers.com or Audit Link jvilker@cuanswers.com or Lender*VP sales@lendervp.com

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