Regulation Z Revisited:
Credit Counseling Required?
Provided by: Chad M. Gentry, Executive Director
Community Credit Counseling Services
Here are a few facts about Regulation Z that you may find interesting:
6.5 ft – The height of the banking regulations changes from 2010 if printed on single sheets of paper and stacked vertically.
270 – The number of pages in Regulation Z Part II issued by the Federal Reserve. (Read it here: http://edocket.access.gpo.gov/2010/pdf/2010-624.pdf)
27 – The number of pages in the summary of coming changes issued in 2009 by CUNA! (Read it here: http://www.cuna.org/download/rcc_101409.pdf)
74 –The number of times Credit Counseling is referenced throughout the regulation.
Given this information, you can start to understand why the credit union industry is feeling the pressure regarding the increased costs of the new regulatory environment. One important measure implemented in Regulation Z is that if you offer your members credit cards (open ended lines of credit), then you are required to provide a 1-800# on card statements in order to connect card holders with at least three credit counseling resources.
How does this 1-800# translate to your credit union from a compliance and cost standpoint?
As of February 2010 your members’ credit card statements are required to provide a contact number to a minimum of three credit counseling resources. These credit counseling resources must be non-profit 501(c)(3) debt management and credit counseling agencies. A qualified agency must:
- Be on the Federal Trustee’s approved list,
- Provide services in the footprint where your clients live,
- Provide qualified and certified counselors,
- Provide adequate provisions for safe keeping of client funds,
- Make all services available to the public regardless of ability to pay,
- Provide trained counselors who receive no commissions.
To make matters even more complicated, the 1-800# itself must fulfill additional qualifications:
- Must provide three credit counseling options that are approved by United States Trustee,
- Must provide websites as an access point to these credit counseling agencies,
- Must provide counselors in the foot print where the member is located,
- Must provide a resource in at least one language other than English.
Many credit unions attempt to fulfill these requirements by offering the phone number to their own customer service department where they have trained credit union staff filter calls and provide resources for credit counseling. Unfortunately, while this may be cost effective in the short term, it is NOT in compliance with the guidelines.
The following non-profit credit counseling services are offered to Mountain West Credit Union Association Members:
- Community Credit Counseling Services is offering there service to Association members throughout Colorado. Contact Chad M. Gentry at 303.233.2773 for more information.
- Take Charge America is a resource available through REAL Solutions. Contact Paul Nichols at Take Charge America at (623) 266-6286 for more information. www.takechargeamerica.org
- GreenPath Debt Solutions is a credit counseling service available through CUNA Strategic Services. Contact email@example.com or 1.866.809.8913 for more information. (In Wyoming was previously known as: Consumer Credit Counseling Service of Northern Colorado and Southeast Wyoming) www.greenpath.com