In April 2011, Morrison & Foerster published the client alert “Summary of Final CARD Act Clarifications.”
On March 18, 2011, the Federal Reserve Board (“FRB”) issued a final rule to clarify certain recent amendments to Regulation Z, particularly those implementing the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“CARD Act”). While the FRB indicated that the rule was intended to enhance consumer protection and to facilitate compliance by resolving areas of uncertainty, the final rule will significantly impact current industry practices and, in some instances, will require issuers to again revise compliance policies and procedures, application and account-opening disclosures, and change in terms notices and other consumer communications.
The effective date, as well as the mandatory compliance date, of the final rule is October 1, 2011. Issuers may, however, comply with the rule prior to the mandatory compliance date.
Click here to read the full alert.