• Significant changes to the terms of your credit card must be given 45 days prior to the change taking affect. Under current rules, credit card companies only needed to give 15 days' notice prior to making certain term changes.
• Over-limit fees will be prohibited unless you consent to pay for the privilege. Your credit card bill will now be due on the same calendar day every month. This means you can schedule payments each month knowing exactly when your bill needs to be paid.
• When you open a new account, your interest rate must stay at the opening rate for at least 12 months. Even if a consumer's rates are raised after 12 months, the increased rate only applies to new purchases - not the balance accrued in the first 12 months. (There are a few exceptions.)
• Statements must be mailed at least 21 days ahead of when they are due. This provides you with more time between when you receive your statement and when your bill is due.
• If you're under 21, it will be difficult to open a new credit card account. You'll need a co-signer or show proof of income.
• You can "opt-out" if you don't like the terms your credit card companies send you. Your card may be closed, but you will have multiple options for paying off your balance, including having up to 5 years to pay the card off - under the terms you had before opting out.
• Other accounts can't be used as the basis for raising your interest rate. This practice known as "universal default", allowed late payment or defaults on other bills (such as utility bills) to be cause for raising your credit card interest rate even though those other accounts are not related to your credit card account.
• Restoring good payment history will lower a raised APR. If you are reported as delinquent on your credit card payments for 60 days your APR can be increased, but it must return to
  the old rate if you make 6 consecutive payments thereafter.
• Payments go towards higher interest rate balances first. For example, if you have a cash advance balance in addition to a regular purchase balance, it's very likely the cash advance
  has a higher interest rate associated with it. When you pay more than your minimum, the excess amount goes toward paying off that higher interest rate balance before the rest of
  your balance.
• It may be harder for those with bad credit to get credit. The Federal Reserve openly recognized that these new rules may make it difficult for those with bad credit or limited credit histories to qualify for a new credit card.
• Increased protection for gift card holders. Gift cards now cannot expire for at least 5 years and no inactivity fees can be assessed unless the gift card goes unused for at least 12 months. 

Compliance with Mass CMR 17.00

Deadline March 1, 2010.  For the full text, please see my Blog entry from February 2nd.  Here is the link. This link also provides links to the actual CMR text.

The bottom line?  This is for all of us! If you have personal information about employees, customers, or anyone involved with your company, you MUST develop and maintain a comprehensive written information security program ("WISP").  The WISP must provide administrative, technical and physical safeguards for the personal information.

If you have questions or need assistance in developing a WISP, please get in touch with us.