Today, Treasury Secretary Timothy Geithner released a statement acknowledging today's implementation of certain new rules under the Credit Card Accountability, Responsibility, and Disclosure Act (Credit CARD Act) signed into law by President Obama last spring, as a "critical step forward in our effort to protect American families by prohibiting the use of unfair retroactive rate hikes and late fee and over-limit fee traps by credit card companies." Certain provisions relating to change-in-terms notice requirements and the amount of time that consumers have to make payments became effective on August 20, 2009. The remaining provisions of the Credit CARD Act take effect on August 22, 2010 and will be the subject of future Federal Reserve rulemaking.

Alston & Bird has issued separate advisories on the Credit CARD Act and on the rules that became effective today.