WASHINGTON (5/14/08)—The Credit Union National Association (CUNA) is concerned about the scope of a regulatory proposal dealing with deceptive practices for credit cards, and overdraft protection plans and is seeking credit union comments. The drafts were published by the National Credit Union Administration (NCUA), along with the Federal Reserve Board and the Office of Thrift Supervision. CUNA will work with its Federal Credit Union Subcommittee, Consumer Protection Subcommittee, and Payments Subcommittee to identify which, if any of the proposals we oppose, support, or recommend be modified. For credit cards, the proposal addresses time periods for making payments, payment allocations, interest rate increases on outstanding balances, fees resulting from credit holds, methods for computing balances subject to interest charges, excessive security deposits and fees charged when credit is issued, and advertisement that include multiple interest rates and multiple credit limits. On overdraft protection plans, the draft requires consumers to be given an opportunity to “opt-out” of the plan, and addresses fees resulting from holds on debit card transactions. CUNA is seeking comment by July 18. Among the questions to be considered:
* Should states be permitted to seek an exemption from the unfair and deceptive practices proposal if the state law provides greater or a substantially similar level of protection, or will this undermine the uniform application of Federal standards? * Regarding the proposal to provide consumers reasonable time to make credit card payments, what is the number of days after the closing date of the billing cycle that you typically mail or deliver periodic statements? * What percentage of your members receive credit card statements by mail and electronically, and what percentage make payments by mail electronically, telephone, or through other means? * Will the 21-day deadline give consumers sufficient time to review the statements and make payments?