On July 22, 2015, the Department amended its MLA regulation, primarily for the purpose of extending the protections of the MLA to a broader range of closed-end and open-end credit
products (the July 2015 Final Rule).
It is also beginning a review of "other potentially high-risk loan products and practices" such as open-end credit
In the case of consumer loans, banks generally follow a uniform charge-off policy set by the banks' regulators: open-end credit
(such as a home equity line of credit) is written off at 180 days delinquency, and closed-end credit (such as an auto loan) is written off at 120 days delinquency.
closed-end extension of credit that does not meet the definition of open-end credit
as an open-end plan.
Oklahoma--Oklahoma's Consumer Credit Code (Title 14A, Section 2-211) says that "no seller in any sales transaction may impose a surcharge on a cardholder who elects an open-end credit
card or debit card account instead of paying by cash, check or similar means"
The plan as a whole, including all its sub-accounts, is designed to be treated as open-end credit
22, 2010, implement parts of the Credit CARD Act passed last May, but don't read too much into that title: Certain advertising provisions in the rule affect all types of consumer open-end credit
plans, not just credit cards.
The amendments principally deal with open-end credit
accounts and require new disclosures on periodic statements and on credit card applications and solicitations.
In part one of this series (September 2004), we reviewed open-end credit
and direct closed end credit.
Finally, to prevent creditors from evading HOEPA requirements, which cover only closed-end loans, creditors are prohibited from wrongfully structuring a home-secured loan as an open-end credit
- These include credit cards, cash advance credit cards and lines of credit, which can be used up to a pre-approved limit.
The alternative is to establish open-end credit
so that funds are available for contingencies, but no expense is incurred unless and until a loss actually occurs.