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New Credit Card Law to Reform Current Industry Practices

June 1, 2009


On May 22, 2009, President Obama signed the Credit Card Accountability, Responsibility and Disclosure Act of 2009 (also referred to as the Credit CARD Act of 2009) (H.R. 627) (the “Act”). This Alert provides an outline of the key provisions of the Act. In general, the Act’s credit card provisions amend the Truth in Lending Act (“TILA”); its prescreening provisions amend the Fair Credit Reporting Act; and its stored value provisions of the Act amend the Electronic Funds Transfer Act (“EFTA”). Several provisions amending TILA and EFTA will require interpretation and rulemaking by the Federal Reserve Board (the “Board”). The Act mandates many of the yet-to-be effective rules already issued by the Board in December 2008, but also imposes additional restrictions. We can expect the Board to build on and expand its December 2008 rules to address the significantly broader scope of the Act.

Practices