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.
Last edited by Andy Z; 09/15/16 09:48 PM.
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?)
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell