Jim Vilker, VP Professional Services February 5 th, 2009

Overview Rate Management Fair Interest Application Payment Applications Statement Changes Disclosures Fees Ability to Repay Rules Affecting Young Consumers Advisor Forum

Why? The Regulation Itself…….Start on pg. 538 Comments, Regulation, Staff Commentary, Appendix reg a1.pdf reg a1.pdf What? CU*BASE CU*BASE Configurations Credit Union Process Credit Union Disclosures When? 90% by February 22 Additional changes due August 2010

January 2009 Federal Reserve Introduces Reg Z changes UDAP is adopted May 2009 Congress passes Credit CARD Act Fed Scrambles July 2009 Federal Reserve issues first interpretation

August day grace period October 2009 Federal Reserve issues second interpretation January 2010 Federal Reserve issues third interpretation 1155 pages UDAP is reversed January Regulation Z changes are reversed and consolidated Federal Reserve issues opinion on floors

Definitions Fixed rate…….. Kind of? What to do about 999 buckets Notice requirements Variable Rates Notice requirements Let’s also talk floors Introductory rate Timely settlement of estates

The rule “defining the event” Notice requirements The timing The configuration

Fair Interest Application Highest to lowest Looking back more than one cycle Interest calculation changes Configuration change requirement

Same day each month What about closed days Delinquency fines….one day? Never Have you configured your open days on they system MNCNFD option 23 What to do on February 28 th What’s on the drawing board

Over-limit a thing of the past “Sure I’ll opt in” Total annual fees cannot exceed 25% Annual fee renewal notice requirement Configuration change requirement

Late Payment Warning Amortization of payments Greater than 3 years Less than or equal to 3 years Not amortizing Credit Counseling

Statements…… what about grace days on back Posting agreements to your website Submitting to the Federal Reserve Consumer Agreements 226.5a College Agreements Small issuer exception File specifications a4.pdf a4.pdf Look to Appendix G

Less than 21 you must Prove independence Co-signed by someone 21 years or older No increases in credit line unless it is agreed to by co-signer

Must take into consideration Debt to income Debt to assets Disposable income Affects on Auto Decisioning Pre-screens Annual increases based upon credit score

Share how you are meeting the requirements Share your policies and disclosures

Time to Simplify Read the Regulation Get going on the disclosures Document your efforts Share