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#1231443 - 08/12/09 02:34 PM Open end credit and new statement requirements
ComplianceisOK Offline
100 Club
ComplianceisOK
Joined: Jan 2005
Posts: 167
Dickinson, ND
Can someone explain this part of the regulation on the statement requirements:

Paragraph 5(b)(2)(ii).

1. 14--day rule. The 14--day rule for mailing or delivering periodic statements does not apply if charges (for example, transaction or activity charges) are imposed regardless of the timing of a periodic statement. The 14--day rule does apply, for example:

• If current debits retroactively become subject to finance charges when the balance is not paid in full by a specified date.

Imposed regardless of the timing of statements - not sure how this works?

PLOC and Ready reserve accounts - we include these statements with the checking statements - we do not impose late fees but would report to CRA if payment is over 30 days late. The statements are not sent 14 (21 days now) in advance but we would not report to the CRA until after the 30 days so we should be OK - is that correct?

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Lending Compliance
#1231857 - 08/12/09 10:01 PM Re: Open end credit and new statement requirements ComplianceisOK
ComplianceisOK Offline
100 Club
ComplianceisOK
Joined: Jan 2005
Posts: 167
Dickinson, ND
Any help?? Anyone combine statements?

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#1231910 - 08/13/09 01:02 AM Re: Open end credit and new statement requirements ComplianceisOK
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
"The statements are not sent 14 (21 days now) in advance but we would not report to the CRA until after the 30 days so we should be OK - is that correct?"

You have to deliver the statements 21 days in advance in order to report the loan to a CRA, regardless of when you actually do the reporting.
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