Most issuers have already taken steps to ensure compliance. It's like when your boss strongly suggests that you come to work on time. It always behooves the industry to pay attention to the federal regulators.
It's not a matter that you're penalized if you're five minutes late with a payment and your interest rate doubles or triples. It involves delinquencies serious enough to show up on your credit report. It means the consumer is exhibiting riskier credit behavior.