We are removing the penalty apr from existing and new OD LOCs. I'm not sure if a change notice is needed under 1026.9(c)(2).
1026.9(c)(2)(v)(A) states a notice is not required "when the change involves charges for documentary evidence; a reduction of any component of a finance or other charge...". The interpretation seems to clarify this statement applies to only Temporary reductions in interest rates or fees. Our change is permanent, can someone confirm if we are required to provide notice?