Alert January 12, 2010

FRB Issues Final Rule on Credit Cards, HELOCs and Private Education Loans

Today, the FRB approved a final rule implementing the changes to Regulation Z required by the Credit Card Accountability Responsibility and Disclosure Act of 2009. The final rule also includes provisions that affect home equity lines of credit subject to Regulation Z (although the final rule does not change the proposed revisions to those portions of Regulation Z affecting HELOCs published on August 26, 2009), as well as previously adopted rules applicable to private education loans. Although the final rule has an effective date of February 22, 2010, the mandatory compliance date is July 1, 2010 for those provisions that are not requirements of the Credit Card Act.