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Dreher Tomkies LLP
Attorneys at Law
2750 Huntington Center
41 South High Street
Columbus, Ohio 43215
Telephone (614) 628-8000
Fax (614) 628-1600



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FEDERAL CREDIT CARD LENDING GUIDANCE ISSUED

The Office of the Comptroller of the Currency, the Board of Governors of the Federal System, the Federal Deposit Insurance Corporation and the Office of Thrift Supervision issued draft account management and loss allowance guidance for credit card lending. The guidance is effective immediately.

The guidance deals with the following issues:

  • Credit line management;
  • Over‑limit practices;
  • Minimum payments and negative amortization;
  • Workout and forbearance practices;
  • Income recognition and loss allowance practices; and
  • Policy exceptions.

The guidance is applicable to all institutions engaged in credit card lending and differs in a few respects from the draft guidance previously released. For example, the repayment period for workout programs has been extended to 60 months.

For a copy of the guidance or for more information regarding this Alert , please contact Mike Tomkies at (614) 628‑1603 or mtomkies@dltlaw.com or Elizabeth Anstaett at (614) 628‑1604 or eanstaett@dltlaw.com .