Comment on CFPB-2012-0039-0001

Genisys Credit Union supports the proposed removal of the independence requirement for consumers of credit cards who are age 21 or older. We believe that this will benefit consumers who 1) otherwise would lack access to an important payment and credit mechanism; and 2) are spouses or partners not employed outside the home and need to establish credit in their own name should they find themselves in different circumstances in the future. The first two examples provided in the proposal seem straightforward. It would be easy to determine and document an individual’s access to funds by either seeing a history of deposits of a household members salary into a joint account or a track record of transfer deposits from the household member’s account into an account that the spouse or partner has access to. We would encourage the Bureau to require no other documentation beyond this simple validation process. The third example appears to pose more difficulty. The requirements to prove that a household member (who does not deposit funds into an accessible account for the spouse or partner) uses their salary to pay for the expenses of the spouse or partner would likely be very difficult to administer. This exception may not be prudent and may lead to disputes as time passes. Genisys supports the extension of these rules to spouses or partners under the age of 21 who are not employed outside of the home. We believe that the targeted marketing of these members should still follow the previous restrictions under Reg Z but that access to credit cards should not be denied under similar circumstances as those in the proposal to those age 21 and over. Properly administering the proposed rules based on age would be difficult for card issuer staff and could subject financial institutions to unwarranted actions for Regulation Z violations.