Consumer protections will be phased in over the next 15 months with the earliest starting Aug. 20, 2009. By that date, all card issuers must begin giving 45-day advance notice of significant changes in card terms. That is also the deadline for giving consumers at least 21 days (instead of the current 14) to pay their monthly credit card bills. (See an interactive timeline of how the bill became law and when its provisions take effect.)
The bulk of the consumer protections -- limiting when interest rates can be increased, banning universal default and double-cycle billing, and restricting credit cards for minors, among others -- take effect Feb. 22, 2010. The timing of the law was a major point of contention during Congressional debate on the bill. Consumer advocates argued families struggling in the recession needed help sooner while banking lobbyists pushed for more time to implement changes in billing, operations and computer systems required by the law.
Provisions for restoring interest rates to previous levels if cardholders show six months of good behavior do not start until Aug. 22, 2010. Making gift cards valid for at least five years and requiring that fees are reasonable also take effect by August 2010.
Federal rules approved by regulators in December 2008 overlap with the new law and cover many but not all of the same practices. Those federal rules take effect July 1, 2010.
Other provisions of the bill include:
* Fines of up to $5,000 for card issuers that violate the act.
* Banning universal default and double-cycle billing.
* Prohibiting over-limit fees unless consumers agree to allow transactions that exceed their credit limits to go through rather than be denied.
* Fees for late payments, over-limit charges or other penalty fees must be reasonable and related to the violation.
* Extending the life of gift cards and gift certificates so that they cannot expire within five years of activation. Banning dormancy or inactivity fees on gift cards unless there has been no activity in a 12-month period.
* Banning credit cards for people under the age of 21 unless they have adult co-signers or show proof that they have the means to repay the debts. College students must get permission from parents or guardians to increase credit limits on joint accounts they hold with those adults. The new law will ban those free pizza and T-shirt giveaways -- popular on many college campuses -- if students sign up for credit cards. Colleges, universities and alumni associations would have to disclose the nature of contracts they sign with credit card marketers allowing access to student and alumni contact information.
* Requiring that card issuers disclose how long it would take to pay off credit card balances if cardholders make only minimum payments each month and how much users would have to pay each month if they want to pay off their balances in 36 months.
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Personally, I don't think that disclosure of onerous, usurious, and blatantly unfair terms in legalese in a 4 point font is enough. There have to be reasonable limits on fees and costs that banks can impose on consumers. Theoretically being able to "take your business elsewhere" isn't sufficient.
YMMV.
Cheers,
Scott.