Regulatory Comment on Credit CARD Act Rule: Advanced Notice and Cancel Requirements

Regulatory Comment on Credit CARD Act Rule: Advanced Notice and Cancel Requirements

The Pew Safe Credit Cards Project submitted comments to the Federal Reserve Board regarding the Board's interim final rules under Regulation Z (Docket No. R-1364). The rules cover advance notice and right to cancel requirements under the Credit CARD Act of 2009. Pew's comments focused on a number of exceptions the Board proposed, which could allow issuers to raise interest rates, change minimum required payment levels and impose potentially large deferred interest charges with little or no advance warning.

Specifically, Pew's comments presented the following key points:

  1. Exceptions to § 226.9 notice requirements for fluctuations in variable interest rates should not apply to any account for which the issuer requires a fixed minimum interest rate to apply.
  2. There is no basis in the Act for the proposed exception to the right to reject changes in terms for increases in minimum required payments, and it should be deleted.
  3. The proposed exception to the requirement to notify cardholders of their right to cancel and avoid interest rate increases or other significant changes in cases where accounts are 60 days past due is unwarranted, and overbroad.
  4. Issuers should be required to provide notice to cardholders within 45 days of the expiration of deferred interest periods.

Download the full PDF for more information.

Spotlight on Mental Health

Composite image of modern city network communication concept

Learn the Basics of Broadband from Our Limited Series

Sign up for our four-week email course on Broadband Basics

Quick View

How does broadband internet reach our homes, phones, and tablets? What kind of infrastructure connects us all together? What are the major barriers to broadband access for American communities?

Pills illustration
Pills illustration

What Is Antibiotic Resistance—and How Can We Fight It?

Sign up for our four-week email series The Race Against Resistance.

Quick View

Antibiotic-resistant bacteria, also known as “superbugs,” are a major threat to modern medicine. But how does resistance work, and what can we do to slow the spread? Read personal stories, expert accounts, and more for the answers to those questions in our four-week email series: Slowing Superbugs.

Explore Pew’s new and improved
Fiscal 50 interactive

Your state's stats are more accessible than ever with our new and improved Fiscal 50 interactive:

  • Maps, trends, and customizable charts
  • 50-state rankings
  • Analysis of what it all means
  • Shareable graphics and downloadable data
  • Proven fiscal policy strategies


Welcome to the new Fiscal 50

Key changes include:

  • State pages that help you keep track of trends in your home state and provide national and regional context.
  • Interactive indicator pages with highly customizable and shareable data visualizations.
  • A Budget Threads feature that offers Pew’s read on the latest state fiscal news.

Learn more about the new and improved Fiscal 50.