On November 4, the Office of the Comptroller of the Currency (“OCC”) released its “Credit Card Lending” booklet of the Comptroller’s Handbook, replacing the outdated booklet issued in October 1996.  A copy can be found here.

The Comptroller’s Handbook is intended as a summary restatement of existing laws, regulations, and policies.  The “Credit Card Lending” booklet applies to examinations of all national banks and federal savings associations (“FSAs”).  Examiners and members of the public are advised to use the booklet as a reference for obtaining an overview on credit card lending.

Highlights of the revised booklet include:

  • Providing updated guidance to examiners on assessing the quantity of risk associated with credit card lending and the quality of credit card lending risk management;
  • Rescinding the following advisory letters, which were largely superseded by the 2009 Credit Card Accountability Responsibility and Disclosure Act (“CARD Act”) and its implementing regulations in Regulation Z:
    • Advisory Letter 2004-4, “Secured Credit Cards” (April 28, 2004)
    • Advisory Letter 2004-10, “Credit Card Practices” (September 14, 2004);
  • Making the following applicable to FSAs:
    • OCC Bulletin 1997-24, “Credit Scoring Models: Examination Guidance” (May 20, 1997); and
  • Addressing the CARD Act, which further amended the Truth in Lending Act.