So much for the CFPB republishing Reg Z and not making any substantive changes. There are a couple things you should know about the CFPB’s version of Reg Z as it will require changes to your current credit card disclosures.
In the CFPB’s new version of Reg Z, there is a significant change to the credit card application and account opening disclosures. (Yes, another one.) The CFPB has amended the reference to the website formerly referring to the Federal Reserve board where consumers may obtain information about shopping for and using credit cards (see page 79845 for the new model forms). The CFPB’s new version of the Reg Z application and account opening tabular disclosures requires a reference to the Bureau. The application and account opening model forms in Appendix G have been revised to reflect this change. Thus, credit unions will need to change their credit card application and account opening disclosures to reflect the CFPB’s amendment. The question is, when does this have to be done?
The CFPB has indicated in the interim final rule that until January 1, 2013, issuers may substitute the required reference to the CFPB with a reference to the website for the Federal Reserve. Thus, credit unions may use their current forms referencing the Fed’s website until January 1, 2013. After that, in order to obtain the safe harbor for using the model forms, credit unions will need to amend their application and account opening disclosures to reference the CFPB’s website.
You will also notice that sections 226.5a (credit card applications and solicitations) and 226.5b (home equity lines of credit) are not in the CFPB’s version of Reg Z. Where did they go? Well, the CFPB has moved them to different places in the regulation. The credit card application and solicitation section (formerly 226.5a) has been renumbered as section 1026.60; the home equity line of credit section (formerly 226.5b) has been renumbered as section 1026.40.