{"id":2702,"date":"2021-12-29T17:44:18","date_gmt":"2021-12-29T17:44:18","guid":{"rendered":"https:\/\/albanknews.com\/?p=2702"},"modified":"2021-12-29T17:44:18","modified_gmt":"2021-12-29T17:44:18","slug":"compliance-qa-open-end-credit-card-and-due-date-considerations","status":"publish","type":"post","link":"https:\/\/albanknews.com\/?p=2702","title":{"rendered":"Compliance Q&A: Open-end Credit Card and Due Date Considerations"},"content":{"rendered":"

Question: <\/strong>For an open-end credit card account, can a due date on the monthly billing statement vary if the usual due date is a Sunday? Example: The due date is usually the 12th of every month. However, 9\/12\/21, is a Sunday, therefore, the billing statement reflects the due date as 9\/13\/21 this month.<\/p>\n

Answer:<\/strong> The answer to this question depends on how the bank determines their due date. The regulation provides the following requirements:<\/p>\n

“6. Same day each month. The requirement that the due date be the same day each month means that the due date must generally be the same numerical date. For example, a consumer’s due date could be the 25th of every month. In contrast, a due date that is the same relative date but not numerical date each month, such as the third Tuesday of the month, generally would not comply with this requirement. However, a consumer’s due date may be the last day of each month, even though that date will not be the same numerical date. For example, if a consumer’s due date is the last day of each month, it will fall on February 28th (or February 29th in a leap year) and on August 31st.<\/p>\n

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  1. Change in due date. A creditor may adjust a consumer’s due date from time to time provided that the new due date will be the same numerical date each month on an ongoing basis. For example, a creditor may choose to honor a consumer’s request to change from a due date that is the 20th of each month to the 5th of each month or may choose to change a consumer’s due date from time to time for operational reasons. See comment 2(a)(4)-3 for guidance on transitional billing cycles.”<\/li>\n<\/ol>\n

    Regulation Z, \u00a7 1026.7(b)(11), Comment 6 \u2013\u00a0 https:\/\/www.consumerfinance.gov\/rules-policy\/regulations\/1026\/7\/#7-b-11-Interp-6<\/a><\/p>\n

    “(A) The due date for a payment. The due date disclosed pursuant to this paragraph shall be the same day of the month for each billing cycle.”<\/p>\n

    Regulation Z, \u00a7 1026.7(b)(11)(i)(A) \u2013 https:\/\/www.consumerfinance.gov\/rules-policy\/regulations\/1026\/7\/#b-11-i-A<\/a><\/p>\n

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    Compliance Alliance<\/strong> offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933<\/strong> or email info@compliancealliance.com<\/a> and ask for our Membership Team.<\/p>\n

    Not a member?<\/strong> Learn more about membership with Compliance Alliance by attending one of our live demos:<\/p>\n