Whats Happening with the Open End Rules?
The change of administration, shifts in power and influence in Congress, the throes of an economic depression and an ongoing process at the Federal Reserve Board to review and revise Truth in Lending rules have formed the “perfect storm” for regulatory upheaval in several areas, not the least of which is the open end portions of Regulation Z. Here’s a synopsis of final rules and proposals affecting open-end credit. • January 29, 2009 – Regulation Z and Regulation AA rules, both effective July 1, 2010. The Reg Z changes made significant changes to non-home-secured open-end credit affecting applications and solicitations, account opening disclosures, periodic statements, change in terms notices and advertisements. The Regulation AA amendments, issued in coordination with the OTS and NCUA, were designed to protect consumers from unfair or deceptive acts or practices affecting consumer credit card accounts under the Federal Trade Commission Act. • May 5, 2009 – The Fed published proposed c
