Future regulations will deal with other provisions of the law that take effect in February and August of 2010.
The 45-day advance notice requirement applies to (a) an increase in any APR other than a properly disclosed introductory rate; in the case of a variable rate, a change in the index; or the cardholder’s failure to comply with the terms of a workout agreement; or, (b) other significant changes in the terms of the agreement (such as increases in fees or finance charges). The notice must be clear and conspicuous and contain a statement of the consumer’s right to cancel the account before the effective date of the change. If a creditor offers a grace period (a period within which consumers may repay an outstanding balance without incurring any additional finance charge), any additional finance charge(s) may not be imposed unless the creditor mails or delivers a statement reflecting the charge(s) at least 21 days before the payment is due to avoid that finance charge.
Increasing disclosure and clearing up confusion help credit card customers make better financial decisions based on full information. These are the types of consumer protections that the proposed Consumer Financial Protection Agency, if enacted through H.R. 3126, could expand to other products such as overdraft loans and payday installment loans.