Summary of 2011 CARD Act Clarifications

摘要

On March 18, 2011, the Federal Reserve Board ("FRB") issued a final rule ("April 2011 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 April 2011 Rule was intended to enhance consumer protection and to facilitate compliance by resolving areas of uncertainty,4 the April 2011 Rule will significantly impact current industry practices and, in some instances, will require issuers again to revise compliance policies and procedures, application and account-opening disclosures, and change-in-terms notices and other consumer communications.