Client Alert

Congressional Agenda Could Accelerate Banking Agency Rules on Unfair Credit Card Practices and Consumer Disclosures Understanding the New Rules

February 03, 2009

V. Gerard Comizio, Chris Daniel, Lawrence D. Kaplan, Kevin L. Petrasic, Azba Habib and Helen Y. Lee

Under legislation recently introduced in Congress, credit card issuers could experience tighter restrictions much sooner than an expected mid-2010 deadline on certain practices found to be unfair by Federal banking agencies under the Federal Trade Commission Act (FTC Act). The legislation, entitled the Credit Cardholders Bill of Rights Act of 2009 (Cardholders Bill of Rights) signals Congress general dissatisfaction with the timing of the effective date and certain other aspects of the joint, final rule (UDAP Regulations) recently issued by the Board of Governors of the Federal Reserve System (Board), the Office of Thrift Supervision (OTS), and the National Credit Union Administration (NCUA) (collectively, the Agencies)

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