Skip to content
GeoDataVision
Thread Options
#1408682 - 06/27/10 06:46 PM Credit cards - pricing info (226.58(c)(8)(ii))
donnac Offline
Platinum Poster
Joined: Feb 2003
Posts: 624
I understand this requirement is the account opening table with the following changes to the account opening table.

1. Delete the reference to the Fed's credit card website.
2. Delete the billing rights information.
3. If the rate is variable, remove the actual rate from the table & state the index + margin (or range of margins).
4. If the rate is fixed, the only changes needed are (1) and (2).

Is my understanding correct or am I missing something?

Thanks.

Return to Top
Lending Compliance
#1409241 - 06/28/10 11:41 PM Re: Credit cards - pricing info (226.58(c)(8)(ii)) donnac
donnac Offline
Platinum Poster
Joined: Feb 2003
Posts: 624
bump

Return to Top
#1411664 - 07/02/10 08:01 PM Re: Credit cards - pricing info (226.58(c)(8)(ii)) donnac
donnac Offline
Platinum Poster
Joined: Feb 2003
Posts: 624
Has anyone looked at the Fed's website that lists the card agreements & the pricing tables? To me, it appears that banks are all over the board on what they're putting in the pricing tables and don't appear to be compliant with the 226.58(c)(8)(ii).

If I understand correctly, all banks must provide the card agreements & pricing information to current customers, even if they don't have to submit the information to the Federal Reserve.

I'd appreciate thoughts on how your bank is complying with the pricing table that you must provide with your card agreements to current customers.

Or, am I totally misunderstanding this requirement?

Thanks.

Return to Top
#1411672 - 07/02/10 08:19 PM Re: Credit cards - pricing info (226.58(c)(8)(ii)) donnac
ahou Offline
Power Poster
ahou
Joined: Aug 2002
Posts: 3,094
You have to provide the agreement that specifically applies to the customer that makes the request. (contains current terms & agreement that applies to his acct)
_________________________
Opinions are my own and not of my employer.

Return to Top
#1411904 - 07/06/10 03:46 PM Re: Credit cards - pricing info (226.58(c)(8)(ii)) ahou
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
I know there is an exemption for posting on the FRB website if you hold less than 10K cards. Doesn't that exemption also apply to our own website posting?
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1412210 - 07/07/10 12:13 AM Re: Credit cards - pricing info (226.58(c)(8)(ii)) RR Joker
donnac Offline
Platinum Poster
Joined: Feb 2003
Posts: 624
Ahou,

Thanks for confirming that we need to provide the information that's specific to the customer requesting the information.

I'm confused regarding the pricing piece that we must provide. Are you providing the account opening table? I thought we had to tweak the account opening table with the items in my first post that started this thread.

Thanks.

Return to Top
#1412267 - 07/07/10 01:33 PM Re: Credit cards - pricing info (226.58(c)(8)(ii)) RR Joker
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
Originally Posted By: RR joker
I know there is an exemption for posting on the FRB website if you hold less than 10K cards. Doesn't that exemption also apply to our own website posting?


I believe I have answered my own question. This exemption apparently applies across the board if you have under 10k card accounts.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1684373 - 03/30/12 06:55 PM Re: Credit cards - pricing info (226.58(c)(8)(ii)) RR Joker
Tarhe Online
Diamond Poster
Joined: Nov 2006
Posts: 1,279
California
As to the above comment (you do not need to post the credit card agreement on the bank's own website if the bank has less than 10,000 cards), where can I find that? I see 226.58 says that any card issuer must post its credit card agreements on its website - but nothing that says you do not need to do this either if you have less than 10,000 cards. The 10,000 threshold seems to apply only to submission to the FRB? We didn't post them because we didn't think we had to, now it is being questioned and we need to support why we didn't post. Thanks!

Return to Top
#1684395 - 03/30/12 07:16 PM Re: Credit cards - pricing info (226.58(c)(8)(ii)) Tarhe
Tarhe Online
Diamond Poster
Joined: Nov 2006
Posts: 1,279
California
Okay, I answered my own question, too. Here goes:

Reg Z, Section 226.58(c)(1) provides that a card issuer must make quarterly submissions of their credit card agreements t the FRB. There is a De minimis exception where a card issuer is not required to submit any credit card agreements to the FRB if the card issuer had fewer than 10,000 open credit card accounts as of the last business day of the calendar quarter.

Section 226.58(d) says that a card issuer must post and maintain on its publicly available website the credit card agreements that the issuer is required to submit to the FRB. Since we do not submit to the FRB under the de minimis exception, we also do not need to post on our website.

Section 225.58(e) says that we must have available an individual cardholder’s agreement by either posting it on our website or promptly providing a copy upon request. We have opted for the second option and provide a copy of the agreement upon request.

Bottom line - our bank does not need to post on our own website.

Return to Top

Moderator:  Andy_Z