HELP! My bank is acquiring another bank that has an in-house credit card portfolio!

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Question:

My bank has just acquired another bank that has its own in-house credit card program. We’ve purposely never done an in-house credit card program because of the sizeable compliance burden of them, but now here we are. What do I need to know for compliance on these acquired cards?

Answer:

First, is your bank going to honor the existing card agreements? If so, get your system ready to match what the product’s disclosures and terms & conditions line out. If not, you’ll need to provide advance notice of the changing account terms. If the changes are deemed to be a “significant change in account terms” per 1026.9, then the consumer has the right to reject the changes. If they do, you can close the card, but you’ll be limited in how you can require the balance to be paid off.