On January 12, 2010, leaving issuers with less than two months to implement extensive requirements, the FRB issued a final rule (“Rule”) to implement the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“CARD Act”). The Rule incorporates the substance of the Regulation Z rule issued by the FRB in January 2009. Because many requirements in the January 2009 rule and amendments to Regulation AA (“UDAP Rule”) are incorporated into this Rule, the FRB simultaneously issued notices withdrawing the January 2009 rule and the UDAP Rule.

Two remaining provisions of the CARD Act were not included in the Rule. Both are currently scheduled to become effective on August 22, 2010. One provision addresses the reasonableness of penalty fees. The other provision requires issuers to evaluate past interest rate increases and reductions twice a year. We expect the FRB to release a proposed rule implementing these provisions in early March 2010.