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Dreher Tomkies LLP
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BOARD ISSUES CARD ACT FINAL RULES

Today the Federal Reserve Board (Board) published a final rule amending Regulation Z to implement the provisions of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act). The rule finalizes the Board’s (i) July 15, 2009 interim final rule implementing CARD Act provisions effective August 20, 2009 and (ii) September 29, 2009 proposed rule implementing CARD Act provisions effective February 22, 2010 (see 74 Fed. Reg. 36077 (July 22, 2009); 74 Fed. Reg. 54124 (Oct. 21, 2009)). A final set of rules implementing CARD Act provisions effective August 22, 2010 will be issued at a later date.

The Board also is withdrawing as unnecessary its final rules amending Regulation Z and Regulation AA published on January 29, 2009, since those rules have been revised for consistency with the CARD Act and incorporated in the new final rule.

In addition, the Board has provided technical specifications for complying with the initial submission requirements of Sections 204 and 305 of the CARD Act, which require card issuers to submit to the Board (i) agreements between the issuer and a consumer under a credit card account for an open-end (not home-secured) consumer credit plan and (ii) an annual report regarding any college credit card agreement to which the issuer is a party, respectively.

Finally, the Board published a new online publication "What You Need to Know: New Credit Card Rules" that explains key changes consumers can expect from their credit card companies as a result of the new rules. The Board plans to release additional "What You Need to Know" publications in conjunction with other major rulemakings.

We will continue to review and analyze the CARD Act rules. Additional information on the rules will follow in future Alerts.

  • Judy Scheiderer