by Bernadette Clair
I hope everyone enjoyed the holiday weekend! Now, it’s back to the grind…
Earlier this month, my colleague JiJi blogged about the CFPB’s final 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 to as 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 now required to 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’s final 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, OR they can choose to limit consideration of a consumer’s income or assets to the consumer’s independent income and assets. (Keep in mind that for consumers under the age of 21, section 1026.51(b)(1)(i) requires card issuers to consider independent ability to pay.)
From the rule:continue reading »