When an employee applies for a variable rate card the applicable current APR is determined, then the employee is given a rate is 2% less that the applicable APR ("employee rate"), and disclosed according TILA. It is also disclosed at account opening that when employee is no longer with the company, that the "employee rate" will increase to the applicable variable APR at that time. While employed, the "employee rate" will always be 2% less than variable APR based on market conditions.. When the employee leaves the company and the "employee rate" is terminated, is the balance at that time "protected" at the "employee rate"?
Any guidance would be greatly appreciated!