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#1689348 - 04/17/12 02:22 PM Reevaluation of Rate Increases 12 CFR 1026.59
Kay Offline
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Joined: Mar 2004
Posts: 248
Midwest
Bank has a variable rate credit card based on prime plus a margin. Bank raised the "margin" in 2011 and provided the 45 day advance notice of the increase in the "margin" to all affected credit card holders.

Can someone verify that the Bank is obligated to comply with 12 CFR 1026.59 Reevaluation of Rate Increases and thereby is required to conduct a review every six months of the "factors" used to determine the margin increase?

The raise in the margin was for the credit card portfolio and not just certain credit card accounts.

I would greatly appreciate a response to my question.
Last edited by Kay; 04/17/12 02:22 PM.
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Lending Compliance
#1689703 - 04/17/12 09:30 PM Re: Reevaluation of Rate Increases 12 CFR 1026.59 Kay
Kay Offline
100 Club
Joined: Mar 2004
Posts: 248
Midwest
Bump

If someone could please comment on the Bank's obligation to "reevaluate" the rate increase every six months due to the fact that Bank has "increased" the margin on a variable rate credit card portfolio.

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#1910111 - 03/31/14 07:11 PM Re: Reevaluation of Rate Increases 12 CFR 1026.59 Kay
river girl Offline
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Joined: Nov 2004
Posts: 1,004
I have the same question please.

We are looking at increasing the margin on our variable rate credit card across the board. Would this require the 6 month look back? I suppose you can see we are increasing it due to market conditions.

We also want to take our non-variable card and make it variable. As soon as the new variable rate goes higher than what the rate was as a non-variable card....that requires the look back also? Forever?

What exactly are we documenting when we do this look back.

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#1928907 - 06/03/14 04:30 PM Re: Reevaluation of Rate Increases 12 CFR 1026.59 river girl
river girl Offline
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Joined: Nov 2004
Posts: 1,004
bump

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#2195957 - 10/19/18 03:28 PM Re: Reevaluation of Rate Increases 12 CFR 1026.59 Kay
k8e Offline
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Joined: Sep 2012
Posts: 110
A thread 6.5 years in the making! I believe the answer is YES - it is subject to review every 6 months if you increase the margin (most likely because of market conditions).

Any one want to confirm?
Last edited by k8e; 10/19/18 03:51 PM.
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