WASHINGTON (4/1/13)--In a new Final Rule Analysis, the Credit Union National Association notes that the Consumer Financial Protection Bureau's recent amendments to Regulation Z will likely benefit some credit card issuers, but should not have a major impact on credit union issuers directly, because credit union fees on members' credit card accounts are typically well below the limit.
Regulation Z generally limits the total amount of fees that an issuer may charge on a consumer's credit card account to 25% of the credit limit in effect when the account is opened.
The CFPB's final rule, which came into effect on March 28, amends Reg Z so that the limitation applies only during the first year after account opening.
The CFPB action specifically amends Section 1026.52 of Reg Z. In the Final Rule Analysis, CUNA Senior Assistant General Counsel for Regulatory Advocacy Luke Martone notes that all methods of compliance under previous regulation remain available to card issuers. The CFPB regulatory measure states that card issuers who were previously in compliance with Section 1026.52(a) of Reg Z "need not take any additional action to remain so."
For the full Final Rule Analysis, use the resource link.