Most provisions of the Credit Card Act of 2009 take effect next February, but some must be implemented in a few short weeks, on Aug. 20. In the coming weeks and months, therefore, bank compliance officers, relevant operations personnel, and executives with responsibility for compliance management have work to do. And as always, each bank's board of directors has ultimate responsibility for overseeing the implementation of the act and the additional regulations that will follow.
Beginning Aug. 20 and subject to only limited exceptions, creditors must provide at least 45 days advance written notice to cardholders regarding annual percentage rate increases and significant changes in finance charges, fees, and other terms the Federal Reserve Board may designate. In addition, as of Aug. 20, creditors that offer a grace period will have to honor it and forego a finance charge unless they have mailed or delivered their periodic statements at least 21 days before the payment due date.