To avoid confusion and duplication with provisions of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (Credit CARD Act) and certain amendments to the Federal Reserve’s Regulation Z, the OTS announced on May 13 that it is removing a part of its rules that deal with unfair consumer credit card account practices.

Nutter Notes: Specifically, the OTS is removing subpart C and the related official commentary from its rule on Unfair or Deceptive Acts or Practices originally adopted in January 2009 under authority granted by the Federal Trade Commission Act and the Home Owners’ Loan Act. The consumer protections contained in the OTS rule are subsumed within the Credit CARD Act and changes to Regulation Z.