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|Arnold Ramirez, Research and Information Consultant for the California and Nevada Credit Union Leagues|
According to Regulation E §1005.20, there are certain conditions that must be met for an issuer or seller of a general-use prepaid card which determine whether an expiration date may be applied.
Before a general-use prepaid card is purchased, the issuer or seller must disclose to the consumer the information about dormancy, inactivity, service fee, expiration date, and the toll-free telephone number. If the issuer or seller has a website, it must also disclose that site so the consumer can obtain fee information.
These disclosures must be made on the card. A disclosure made in an accompanying terms-and-conditions document—or on the packaging surrounding a certificate or card, or on a sticker or other label affixed to the certificate or card—does not constitute a disclosure on the certificate or card.
The fees—and terms and conditions of expiration—that are required to be disclosed prior to purchase may not be changed after purchase.
UNCLAIMED PROPERTY REPORTS DEADLINE
updated 10/13/15 12:31 PM
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Credit unions are reminded that Unclaimed Property Holder Notice Reports are due to the California State Controller’s Office (SCO) before Nov. 1 for accounts and property with no activity for the past three years.
COMPLIANCE ROUNDUP: ALERTS, GUIDANCE
updated 10/06/15 09:09 AM
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Federal credit unions can continue to make payday alternative loans (PALs) under changes to the Military Lending Act (MLA), which became effective Thursday, according to the Credit Union National Association (CUNA).