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We posed the question last week as to whether you have to send a change in terms notice for your credit card disclosures when the website on the disclosures changes from the Federal Reserve to the CFPB. The answer? If you don’t want to risk violating Reg Z, then you should send a change in terms notice as it is technically a significant change under Reg Z.
CUNA recently posted an updated blog on the issue on August 9. So, the question now is, if I have to send a change in terms notice, what are the requirements of the notice?
Under Reg Z section 1026.9, you should include the following information in your notice:
( 1 ) A summary of the changes;
( 2 ) A statement that changes are being made to the account;
( 3 ) The date the changes will become effective; and
( 4 ) If applicable, a statement that the consumer may find additional information about the summarized changes, and other changes to the account, in the notice.
The disclosure also must be in tabular format and it may be included on or with the credit card periodic statment. The craziest part of this change in terms notice . . . it technically requires a right to reject! As we stated before, we are working with CUNA to get a clear answer from the CFPB on the practicality of sending this notice. So, stay tuned!
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