Credit card compliance is comprehensive! It isn’t enough to just be up to speed with Reg Z’s open-end rules. Credit card issuers must also be well versed in:
Reg Z’s special credit card provisions, including:
Card issuance
Errors and disputes, including claims for dissatisfaction with goods and services
Prohibition on right of offset
Prompt crediting of refunds
The Credit Card Accountability, Responsibility, and Disclosure Act (Credit CARD Act) provisions, including:
Advance notice for account changes and consumer’s right to reject changes
Periodic statement delivery, disclosure, and content requirements
Payments: minimum amounts, allocation, and cut-offs
Limitations on certain fees, finance charges, and increases in APR
Over-the-limits rule
Ability to Repay requirements
Special rules for “underage” consumers less than 21 years old
Application and solicitation requirements
Differences between credit cards, charge cards, and hybrid prepaid-credit cards
SCRA and MLA relevance on credit card lending
FCRA considerations, including:
Pre-approved offers of credit (prescreening)
Risk Based Pricing Notices or Credit Score Disclosures
Accurate reporting to credit bureaus
Reg B and Fair Lending considerations
Joint owners / Guarantors / Authorized signers
Decisioning tools
Adverse Actions
E-SIGN considerations
Community Reinvestment Act considerations
1071 coverage of business credit cards
UDAP and card rewards programs
Oldies but goodies: BSA / OFAC / CIP / COBO
How do vendors fit in?
Duties and responsibilities – crucial!
Wow! That IS a lot! Get the scoop from a veteran compliance pro (25 years!) who has helped implement compliance credit card programs (from the ground up) in banks of differing sizes. She wrote this program specifically to help the compliance professional who, like her, had no idea where to even begin!