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#190957 - 05/17/04 07:31 PM Cr Card application
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
My cr card servicer's attorney says we do not need to disclose on our cr card application the name of the method used to determine the balance upon which the fin chg is based, (average daily bal including purchases). Is he right?
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Lending Compliance
#190958 - 05/17/04 07:43 PM Re: Cr Card application
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
If the explanation is present in the box instead of the name, yes. 226.5a(b)(6)
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#190959 - 05/17/04 08:01 PM Re: Cr Card application
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
They plan on providing neither the explanation or the name of the method.
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#190960 - 05/17/04 08:14 PM Re: Cr Card application
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Then I disagree with the attorney.

From the OSC 226.5a(b)(6):

5a(b)(6) Balance Computation Method

1. Form of disclosure. In cases where the card issuer uses a balance calculation method that is identified by name in the regulation, the card issuer may only disclose the name of the method in the table. In cases where the card issuer uses a balance computation method that is not identified by name in the regulation, the disclosure in the table should clearly explain the method (emphasis mine) in as much detail as set forth in the descriptions of balance methods in section 226.5a(g). The explanation need not be as detailed as that required for the disclosures under §226.6(a)(3). (See the commentary to §226.5a(g) for guidance on particular methods.)
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The opinions expressed are mine and they are not to be taken as legal advice.

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