For "take-one" credit card applications that are made available to the general public (at islands in the teller area, loan officers desks, etc), the commentary states that "the disclosures...must be current as of the time they are made available to the public. Disclosures are considered to be made available at the time they are placed in public locations (in the case of take-ones)."

I am a little confused by that. Are they "placed in public locations" when marketing put them there (perhaps two years ago)? That seems to mean that the applications could stay there for infinity, so long as they were accurate when they were placed there.

To me, this means that if you change the terms of the credit card such that the disclosure requires updating, you should remove and destroy any existing stock and replace with the newer version. This would require that you keep track of where you are placing the applications.