Strategies for Implementing
Regulatory Change:
Spotlight on the
Credit CARD Act
of 2009
By DAnieLLe M. AngerMeier, CrCM, CrP, CiPP, CAMs,
AnD MiChAeL s. LAMBerth, CPA, CrCM, CiPP, CAMs
Just when you thought you had finally figured out the new regulatory requirements
of the Regulation Z and Regulation AA changes announced last year, Congress passed
the Credit Card Accountability, Responsibility and Disclosure Act of 2009 (CARD). The
amendments reflect a fairly complex implementation approach, with four key compli-
ance dates that creditors must manage to meet (see Exhibit 1 on the next page).
As of this writing, the industry still awaits the Federal Reserve Board’s final require-
ments on CARD. In the meantime, it is abundantly clear that the face of Truth in
Lending has undergone plastic surgery. The fundamentals remain the same, but the
look and feel have changed. Compliance professionals are deeply involved in assessing
the magnitude of the changes, and this is a great opportunity to provide some basic
steps on how to implement a set of changes more complex and comprehensive than
any seen since Reg. Z was conceived in 1969.
