Good for you, wish we were that lucky! I saw the below in the final, make sure you all can provide the below even if you fall under the 10,000 exception.
Similarly, the final rule provides that card issuers with fewer than 10,000 open credit card accounts are not required to submit agreements to the Board, and provides for other exceptions from the requirement to submit agreements. However, the Board
believes that the benefit of increased transparency associated with providing an individual cardholder with access to his or her specific credit card agreement is substantial regardless of the whether the card issuer is required to submit the agreement
to the Board for posting on the Board’s Web site. The Board believes that this benefit of increased transparency for consumers outweighs the administrative burden on issuers of
providing such access, and therefore § 226.58(e) in the final rule does not include the exceptions from the requirement to submit agreements to the Board under § 226.58(c).
Okay, so I was relieved to read in 226.58 the de minimum exception for posting agreements to the Board since we have fewer than 10,000 open accounts. However, I want to make sure that I am correct in my understanding that we get the same exception for posting to our website? It seems like the deminimus applies to both (pg. 452), but then it's not so clear in other parts of the final rule.