Jim Vilker, VP Professional ServicesFebruary 5th, 2009

OverviewRate ManagementFair Interest ApplicationPayment ApplicationsStatement ChangesDisclosuresFeesAbility to RepayRules Affecting Young ConsumersAdvisor Forum

Why? The Regulation Itself…….Start on pg. 538Comments, Regulation, Staff Commentary, Appendix http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20100112a1.pdf

What? CU*BASECU*BASE ConfigurationsCredit Union ProcessCredit Union Disclosures

When? 90% by February 22Additional changes due August 2010

January 2009Federal Reserve Introduces Reg Z changesUDAP is adopted

May 2009Congress passes Credit CARD ActFed Scrambles

July 2009Federal Reserve issues first interpretation

August 200921 day grace period

October 2009Federal Reserve issues second interpretation

January 2010Federal Reserve issues third interpretation 1155 pagesUDAP is reversedJanuary Regulation Z changes are reversed and consolidatedFederal Reserve issues opinion on floors

DefinitionsFixed rate…….. Kind of?What to do about 999 bucketsNotice requirements

Variable RatesNotice requirementsLet’s also talk floors

Introductory rateTimely settlement of estates

The rule “defining the event”Notice requirementsThe timingThe configuration

Fair Interest ApplicationHighest to lowestLooking back more than one cycleInterest calculation changesConfiguration change requirement

Same day each monthWhat about closed daysDelinquency fines….one day? NeverHave you configured your open days on they system MNCNFD option 23What to do on February 28th

What’s on the drawing board

Over-limit a thing of the past“Sure I’ll opt in”

Total annual fees cannot exceed 25%Annual fee renewal notice requirementConfiguration change requirement

Late Payment WarningAmortization of payments

Greater than 3 yearsLess than or equal to 3 yearsNot amortizing

Credit Counseling http://www.nfcc.org/FirstStep/firststep_01.cfm

Statements…… what about grace days on backPosting agreements to your website 226.58Submitting to the Federal Reserve

Consumer Agreements 226.5aCollege AgreementsSmall issuer exceptionFile specifications http://federalreserve.gov/newsevents/press/bcreg/bcreg20100112a4.pdf

Look to Appendix G

Less than 21 you mustProve independenceCo-signed by someone 21 years or older

No increases in credit line unless it is agreed to by co-signer

Must take into considerationDebt to incomeDebt to assetsDisposable income

Affects on Auto DecisioningPre-screensAnnual increases based upon credit score

Share how you are meeting the requirementsShare your policies and disclosures

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Time to SimplifyRead the RegulationGet going on the disclosuresDocument your effortsShare