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#1781672 - 01/31/13 04:51 PM Credit Card Minimum Payment Disclosure
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Las Vegas, NV
I am struggling with the 36 month repayment amount disclosure. We are disclosing that the if only the minimum payment is made it will take 4 years to payoff the balance, but we have not included the 36 month payment amount and total savings. This is because using the same minimum monthly payment every month, it will payoff the balance in less than 36 months (the minimum payment for this month was high because of a larger average daily balance that was reduced by a large payment near the end of the statement period).

I think we still need to make a disclosure of the actual monthly payment amount it will take to payoff the balance in 36 months, as well as the savings. Am I wrong?

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#1783342 - 02/06/13 05:15 PM Re: Credit Card Minimum Payment Disclosure Need Help
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Bounce!

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#1783362 - 02/06/13 05:54 PM Re: Credit Card Minimum Payment Disclosure Need Help
Derwood Offline
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There are three circumstance in which the 36 month disclsore is not required. They are listed in 1026.7(b)(12)(i)(F)(2). It appears that the second exemption may apply in this case:

( ii ) The estimated monthly payment for repayment in 36 months, as described in Appendix M1 to this part, after rounding as set forth in paragraph (b)(12)(i)(F)( 1 )( i ) of this section that is calculated for a particular billing cycle is less than the minimum payment required for the plan for that billing cycle;
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#1783379 - 02/06/13 06:21 PM Re: Credit Card Minimum Payment Disclosure Need Help
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Thank you. I did look at that, but there is an and

which goes on - and ( iii ) A billing cycle where an account has both a balance in a revolving feature where the required minimum payments for this feature will not amortize that balance in a fixed amount of time specified in the account agreement and a balance in a fixed repayment feature where the required minimum payment for this fixed repayment feature will amortize that balance in a fixed amount of time specified in the account agreement which is less than 36 months.

(iii) does not apply - and based on the and I don't think (ii) can apply without (iii)

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#1783400 - 02/06/13 06:54 PM Re: Credit Card Minimum Payment Disclosure Need Help
Derwood Offline
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I saw that and it confused me at first so I went back to the discussion in the Federal Register where final rule was published. http://www.bankersonline.com/topstory/75fedreg/75FR7658.pdf
The discussion on page 7681 is in regards to the exemptions. After reading this it appears the "and" is only meant to signal an additional exemption not an additional requirement to (ii) and they probably should have said "or".
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#1783723 - 02/07/13 04:39 PM Re: Credit Card Minimum Payment Disclosure Need Help
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Thank you Derwood - now it makes sense to me. Don't know why they put the "and" in there.

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