by Bernadette Clair
I hope everyone enjoyed the holiday weekend! Now, it’s back to the grind…
Earlier this month, my colleague JiJibloggedabout the CFPB’sfinal ruleamending Regulation Z’s ability to pay rules for credit cards. For consumers age 21 and over, these changes allow credit unions and other card issuers to consider income and assets that a consumer has areasonable expectation of access toas the consumer’s income or assets.
We’ve received questions from quite a few folks about this change – in particular, whether a credit union is nowrequiredto include the income and assets that a consumer has a reasonable expectation of access to when considering a consumer’s ability to pay.Answer: No.
Under the CFPB’sfinal rule, card issuers can choose to establish lending policies and procedures that consider income and assets to which a consumer age 21 and over has a reasonable expectation of access,ORthey can choose tolimit consideration of a consumer’s income or assets to the consumer’sindependentincome and assets. (Keep in mind that for consumers under the age of 21, section1026.51(b)(1)(i)requires card issuers to consider independent ability to pay.)
From the rule:
