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Chase gets 18 months to comply with new (Reg. Z) rules — But, customers should only need 15 days to comply with Chase’s new rules

According to a letter dated July 17, 2008, from Andrew T. Semmelman, Senior Vice President and Associate General Counsel for “Chase Bank USA, N.A. (“Chase”), the consumer credit card bank subsidiary of JPMorgan Chase & Co.,” written to Jennifer J. Johnson, Secretary, Board of Governors of the Federal Reserve System, Chase’s credit card portfolio consisted of  “over 156 million cards issued.” I think the following points are relevant:

Mr. Semmelman expressed that Chase “appreciates the opportunity to comment on the additional proposed revisions to amend Regulation Z.”  In comparing the comments in the letter with the provisions of Regulation Z, there are certainly some similarities that consumers should find troubling relative to a process that allows those being regulated to influence the rules under which they would operate.  For instance, we now know that it will take 18 months before consumers gain any benefits whatsoever from the newly passed rules under Regulation Z.  Isn’t it convenient that Mr. Semmelman stated: “we urge the Board to allow creditors at least 18 months from the effective date to comply with the Final Reg. Z Rule.”  While he suggested that it would take time to gear up to comply with any new rules, I note that it took hardly any time at all for Chase to launch a massive attack on hundreds of thousands of customers (Chase has been noticeably vague about an exact number) relative to changing the rules with which account holders would have to comply, within 45 days! (raising minimum payments from 2% to 5%, and so forth; see my letter).

By the way, Chase would have preferred that the notice period for new rules with which its customers would have to comply to be only 15 days.  Humm, Chase gets 18 months, but you, the taxpaying consumer who is “bailing out” Chase while at the same time having to endure being bludgeoned by its tyrannical new rules, well, you should only need a “15-day notice.”  Yeah, like I’m really going to find approximately $12,000.00 in 15 days.

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