I have been asked if it is possible to transfer a FR Credit Card to a VR CCproduct and disclose that the Card will remain at a fixed rate until such time the prime rate adjusts at which time the card will become a VR Card tied to an index with a specific margin which will be disclosed.. Is this a possibility?

55(b)(2) Variable rate exception

4. Changing a non-variable rate to a variable rate. Section 1026.55 generally prohibits a card issuer from changing a non-variable annual percentage rate to a variable annual percentage rate because such a change can result in an increase. However, a card issuer may change a non-variable rate to a variable rate to the extent permitted by one of the exceptions in §1026.55(b). For example, §1026.55(b)(1) permits a card issuer to change a non-variable rate to a variable rate upon expiration of a specified period of time. Similarly, following the first year after the account is opened, §1026.55(b)(3) permits a card issuer to change a non-variable rate to a variable rate with respect to new transactions (after complying with the notice requirements in §1026.9(b), (c) or (g)).