Any LaserPro users here?

If you charge a Inactive Fee ( A fee when the account has not been used in the past 12 months) where are you disclosing it?

When we choose the "Inactivity Fee" option, it places it in the "Set up and Maintenance Fees" box of the new form and then has this nice disclaimer:

NOTICE: Some of these set up and maintenance fees will be accessed before you begin using your account and will reduce the amount of credit you initially have available. Based on your initial lomit of $______, your credit limit will only be $_____.

You may still reject this plan, provided that you have not yet used the account or paid a fee after receiving a billing statement. If you do reject this plan, you are not responsible for any of these fees or charges.

Joker, I've missed something - I thought the only statement changes were to credit cards. 226.7(b)(14) applies to all open-end(not home secured) consumer credit plans but it only applies to a deferred interest disclosure. Please tell me what statement changes should occur on the loan side - not credit cards - where I can find that.

226.7(b) 226.8 & 226.9 cover both cr cards & LOC.

226.7(b)(11)&(12) only apply to cr cards. Read 226.7(b)(13) carefully - most of it applies to cr cards except for the ending bal.

So basically, unless changes are being made to the account - the statement changes involve:
1. the way we disclose transactions
2. the format - grouping together certain items.

I thought it was so nice of the regulators to give us that handy little chart at the beginning - but it apparently doesn't cover everything.

I just reviewed a statement produced by our vendor for our open ended non home secured line of credit. Everything seems to be correct but I question the statement peridoic rates may vary. They don't use those terms. By each daily periodic rate they have a (v) then at the bottom it states (v)= variable rate. Will this cause a problem?

Don't forget about the required terminology "Interest Charge" and "Interest Charged" plus "Total Interest", "Fees" and "Balance Subject to Interest Rate". Of course use "Annual Percentage Rate" too.

ahkcompliance, there is no required terminology for the variable rate disclosure - so you're ok.

Great! I didn't think there was any required terminology but wasn't sure. It has always been peridoic rates may vary.

We use LPL - we don't have an activity fee but do have an annual fee. We were fighting that NOTICE as well, but finally figured out we needed to go back in and enter a minimum credit limit for the plan (not for the line but for the product itself) because the 15% calculation is off of the plan minimum which we had at -0- and was triggering the NOTICE. Once we set our minimum, the NOTICE no longer appeared. Hope this helps.

Does anyone know if this change applies to an overdraft line of credit attached to a checking account?

Yes, we made the required changes to our overdraft line of credit that is tied to a checking.

Thanks, ahou, for your help and your lists. I took your list of sections that impact each and made a little book of sections that affect our open-end credit products non RE secured and another book for our HELOCs. We don't have credit cards.

Does the 45 day notice of default rate only apply to consumer unsecured RLOC's or would it also apply to a consumer RLOC secured by a certificate of deposit?

Thanks for any replys

I could be wrong, but I think it applies to anything other than RE secured.

I would agree to that as well.

Our programmers are struggling with th "Interest Charge Calculation" Box on the bottom of the periodic statement. We have PLOCs that may have a rate change during the statement cycle. We are identifying the rate change in the Interest Charged section, but cannot break down the different balances to identify what rate applied to what balance in the Interest Charged Calculation on the bottom. Our vendor has endorsed and provided a weighted rate and weighted balance for that section. Is this an acceptable solution?
Also, is it possible that this int. calculation box only applies to credit cards and I missed that? This is very difficult for PLOCs. Appreciate any input or help.

Deena, thanks for your response.

Is everyone keeping the phrase "finance charge" in credit line agreements for section 226.6(b) disclosures that will be provided on or after 7/1/10? Will you provide any explanation in the credit line agreements to explain that the term "interest charge" will appear on the periodic statements?

I've been looking at section 226.5(a)(2)(i) which says "Terminology used in providing the disclosures required by this subpart shall be consistent." Comment 4 of the OSC to this section says "Language used in disclosures required by this subpart must be close enough in meaning to relate the different disclosures; however, the language need not be identical."

Section 226.4 of Reg. Z still refers to finance charges and section 226.6(b) does not mandate the phrase interest charge except for the table required for credit card plans.

We have some loans set up as revolving lines of credit attached to a checking account for overdraft protection - I did not consider these accounts when looking at the Reg Z open end changes because they are consumer loans that are extended annually - should they be considered because they are revolving?

We have a RR account (with no actual maturity) that is tied like your's is and I had to make changes to our account opening disclosures, so I would say yes. The Schumer box content is what changed.

I'm sorry to ask such a simple question but we cannot seem to agree here on what needs to be disclosed as the ending balance (and thus the previous balance)on our overdraft LOCs. Some say that it's only the principal balance while others believe that it includes the interest due (our methodology does not seem to fit the one described in the OSC at 7(a)(1)3). What ending balance are others disclosing?

Thanks that helped!!

I was going to make a brief power point pres pertaining to the Reg Z changes eff on 7/1 to present to the lenders at a loan committee meeting tomorrow, but I am drowning in month-end and qtr-end stuff!

Has anyone already created a similar piece they would be willing to share?

We have an open-end consumer (not home secured) loan that is called Write a Loan. They access the line by writing a check. They do not have a credit card. It is not tied to their checking account.

We do not have to comply with 12 CFR 226.9(b)(3)... or do we?

Did anyone create a communication piece to customers about the changes to their statement and the terminology? If so, would you be willing to share?

Are there any Fiserv banks that offer a DDL product?