Does anyone know how the MAPR limit of 36% works with deferred interest plans? We have a credit card product with either a 6 or 12 month deferred interest plan. If account holders do not pay off their balance within the promotional period, and are then charged the deferred interest, should that interest be included in the MAPR calculation and therefore be capped?

I haven't been able to locate any commentary or guidance around this scenario.

stanner

I believe you need to calculate the interest charged for each statement cycle and ensure that the MAPR doesn't exceed 36%.

Look at the method for computing the MAPR https://www.bankersonline.com/regulations/32-232-004
and how you actually calculate it under 1026.14 https://www.bankersonline.com/regulations/12-1026-014
hope that helps.