In reading the requirements under 1026.9(g) the notice requirements seem to apply for increase in rates due to delinquency, default or as a penalty. I don’t see anything that indicates that it is only required if a penalty rate such as would be disclosed in the credit card disclosures under 1026.6(b)(2)(D)(1). The loss of the intro rate in our product falls under the disclosure required by 1026.6(b)(2)(D)(2).

Now, when reading through the different examples it does seem to refer to the penalty rate that is applied to the account due to delinquency.

I don’t want to make the bank comply with something that is not necessary, especially if requiring a 45-day notice would extend the time before we could assess the higher interest rate (standard rate).

Please advise…does the 45-day advance notice requirements of 1026.9(g) apply to the loss of an introductory APR that will default to the standard APR for payments that are more than 60 days late? Or is the rate just increased and we move on with no notice requirements?

Wow...my questions must be awful...I haven't been getting answers lately...lol!