The Credit Card Act & Reg Z: The Aftermath

The initial results are in! For the majority of our credit unions with open-end loans, the loans are appearing on the monthly member statements as anticipated; however, we have uncovered two situations that could have prevented some open-end loans from appearing on the monthly statements.

Situation One: A statement parameter that controls whether all of a member's accounts appear on a monthly statement if any one account is flagged for monthly was not set correctly. Credit unions without share drafts may not have had this set to include all of the accounts. If this parameter was not set to include all accounts, then the open-end loans were not flagged to receive a monthly statement.

Please review your Control-Master parameters (Back Office > Standard > Parameters > Control-Master) option, All Member Accounts On Monthly Statements. If it is not selected, then Situation One applies to your credit union.

IMPORTANT: Situation One does not require any further action on your part. CBS is working on an update to handle this configuration starting with the September month-end.

Situation Two: Some credit unions use open-end disclosures, but code the loans as closed-end on the CAMS-ii system. If the loans were coded as closed-end, then CAMS-ii did not set them to monthly and create the adjusted Reg Z monthly payment amount or due date with the Reg Z update from last week.

If Situation Two applies your credit union, please submit an issue via the CBS Issue Tracking System (e-mails or telephone calls are not accepted) with the phrase, Open-end coded as Closed-end, in the Issue Summary. CBS personnel will help you analyze the situation and guide you in the solution.

Thank you

Reg Z Changes Deployed and Loan Re-Amortizations

IMPORTANT: Please read this entire posting. It consists of two parts: Reg Z Software Changes and Effective Date and Notifiyng CBS About Loan Re-Amortizations.

Reg Z Software Changes and Effective Date

Last night, August 26, 2009, CBS deployed the Reg Z Open-End Loan software changes to those credit unions that did not opt out of these program changes. These changes will take effect tonight, August 27, 2009 at the completion of the end-of-day batch processing.

For any questions concerning these changes, please consult the FAQs attached to the previous posting. Otherwise, please address all questions/comments concerning the Reg Z changes to the CBS Issue Tracking System.

Re-Amortizing Loans

Notify CBS immediately (via the Issue Tracking System with the word, Re-Amortize in the Summary section -- no calls or e-mails) if CAMS-ii is set up, or will be set up, to re-amortize any loan payments for your credit union for this month-end, August 2009.

With the changes for the Reg Z and the Credit Card Act, we want to ensure that everything is installed and set up correctly. If you do not re-amortize loans or do not plan to re-amortize loans for this month-end, August 2009, this does NOT apply to your credit union.

This request applies to your credit union if you have a date in the Payment Effective Date text box in the New Rate Settings section of the Account Type Code and Rate Maintenance Screen (Back Office > Standard > Parameters > Account Type/Rates Maint > Loans) for a particular loan account type. You must contact CBS via the Issue Tracking System by typing the word, Re-Amortize in the Summary section of the Issue. Please inculde the Account Type numbers in the Description section.

Thank you