Q: What if the credit card contract does not allow index replacement until LIBOR is unavailable?
A: As discussed above in LIBOR Credit Card FAQ 3, a card issuer may only replace the index on a credit card account if certain conditions are met. Relevant to the LIBOR transition, two options for replacing the index for a credit card are: 1) when LIBOR is unavailable (Unavailable Provision) or 2) on or after April 1, 2022, (LIBOR-Specific Provision). Contractual language may limit which option in Regulation Z a card issuer may use, and which replacement indices may be selected. Contractual language may also require a card issuer to wait until LIBOR is unavailable before it replaces the index. Comment 55(b)(7)-1.