The following is an excerpt from an article contributed to Credit Union Management.
For many, preparing for this summer’s CARD Act deadline was - and continues to be - a challenging task.
Whereas large issuers have the support of third-party systems managers with hundreds of analysts working on their behalf, a number of credit unions have struggled to achieve compliance.
Adding an extra layer of stress was the requirement that issuers give their cardholders 45 days advance notice of any significant changes to the terms or an increase in the minimum payment.
If, for example, a credit union determined an immediate shift from fixed-rate to variable-rate offerings was the only way it could sustain a healthy card program - a move we witnessed the major issuers make this summer - it was a decision they needed to make fast, before they were governed by the 45-day advance notice requirement that took effect Aug. 20.
To add complexity, most credit unions are governed by state regulations that are in many cases even more stringent than the new 45-day rule issued by the federal government. In my home state of Iowa, for instance, credit unions must give their cardholders 60 days advance notice of any change in terms.
Credit unions that waited to make necessary changes to their credit card products may have been faced with the marketing challenge of introducing rate changes during a critical spending time - the holiday shopping season.
Looking ahead to February, credit unions must now prepare to comply with regulations governing rate increases, fees, promotions and payment allocations among others. Most definitely, these changes to the law will bring up requests for clarification.
Credit unions that wish to stay in the game need to move fast, of course. But more importantly, they must remain true to their core philosophy, working through the chaos to instill calm, stability and trust among members.
To read the entire article, click here.


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