As a result, card issuers are no longer required to consider whether consumers age 21 or older
have an independent ability to pay; instead, card issuers are now required by Regulation Z to
consider the consumer’s ability to pay. Second, in determining a consumer’s ability to pay, the
final rule permits issuers to consider income or assets to which an applicant or accountholder
who is 21 or older – and thus subject to § 1026.51(a) rather than § 1026.51(b) ‒ has a reasonable
expectation of access
http://files.consumerfinance.gov/f/201304_cfpb_credit-card-ability-to-pay-final-rule.pdf
