While the stay for the Payday Lending Rule is still in place, I am seeking clarification for open-end credit product offering. I understand applicability hinges on cost of credit exceeding 36% either at consummation or at the end of billing cycle or when in any billing cycle a finance charge is imposed when the principal balance is $0 along with the leveraged payment mechanism.

In reading the commentary from 1041.3(b)(3), my question is if in the same billing cycle the open-end credit product has a $0 principal balance, and trailing interest is assessed, along with a monthly membership fee, would the Rule apply? When I look to 1026.4(c)(4), fees charged for participation in a credit plan is excluded from being a finance charge.

Thank you.

Just for my own benefit, can you explain how you have trailing interest assessed on an open-end credit product? Thanks.