I haven't studied the open-end enough yet, but what you are describing is usurious and simply says we'll violate the law, but make it up to you next month. As I read that section I saw a trial run and anticipated rate of >36% with a fee reduction calculated immediately so the final statement would not exceed the MAPR required.
This will also lead to a lot of calls wanting explanations and some attorney saying "but you charged it..." I would seriously seek counsel's opinion.
(Unless a cure period exists such as with TRID, this sounds dangerous and requiresmore follow up the next cycle. WHat if the account terminates that statement?)
Last edited by Andy Z; 09/15/16 09:48 PM.
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AndyZ CRCM
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