ALEXANDRIA, Va. (8/18/09)--In a recent National Credit Union Administration (NCUA) legal opinion letter, the agency said that a so-called “courtesy period” that follows the payment due date for a credit account does not constitute a grace period under the Credit Card Accountability, Responsibility, and Disclosure (CARD) Act. NCUA Associate General Counsel Sheila Albin wrote that the CARD Act prevents creditors from treating credit account payments as late unless the creditor has “reasonable procedures” to ensure that account statements are delivered to the consumer “at least 21 days before the payment due date or the date on which the grace period expires.” The CARD Act and recent amendments to Regulation Z (Truth in Lending) also do not require federal credit unions “to disclose any period after the payment due date before which late fees are actually imposed,” Albin wrote. Albin also addressed nonmember loan servicing in a separate comment letter, telling an executive from Government of Guam Employees FCU that his credit union lacks the authority to provide loan servicing and collection services directly or through the assistance of a credit union service organization. However, Albin noted, the organization that this FCU wishes to assist, which in this case is the Guam chapter of Habitat for Humanity, could work with the credit union if it becomes a member of that credit union. The credit union could also donate the sought after lending program assistance as an “in-kind, charitable contribution or donation” if Habitat for Humanity does not qualify for membership in the credit union. To read either of the complete letters, use the resource links below.