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#40502 - 11/04/02 02:30 PM open-end consumer credit disclosures
Pale Rider Offline
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My loan ops people tell me it would be better for them to mail separate from the periodic statement the required disclosures for a consumer line of credit. The regs indicate these disclosures must be "on or with" the statement. So, does a separate mailing violate this language?
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#40503 - 11/04/02 02:58 PM Re: open-end consumer credit disclosures
Dan Persfull Offline
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Which required notice are you asking about? Billing Rights, grace period, variable rate info., etc.?
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#40504 - 11/04/02 03:14 PM Re: open-end consumer credit disclosures
Pale Rider Offline
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Well that would be helpful if I was more specific. The disclosures they would like to send separate are the billing rights, apr calculation, index id, and those that are not on the face of the statement. Thanks for your response.
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#40505 - 11/04/02 03:29 PM Re: open-end consumer credit disclosures
Dan Persfull Offline
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As long as your statments comply with 226.7 & 8. I didn't see any prohibition from having the other information on a separate disclosure enclosed with the statment.

If you decide to do this, first I'd look at the cost factor, I would make sure the notices are clearly marked such as "Important Information Pertaining to Your Account". And to make sure there is a quality assurance procedure in place to make sure they are included with each statement.
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#40506 - 11/04/02 03:36 PM Re: open-end consumer credit disclosures
Dan Persfull Offline
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Bloomington, IN
I just re-read your question and I want to clarify something. IMO, these notices should be included with your monthly periodic statements and not mailed "separately" in their own mailing (other than the annual billing rights notice if you choose to send it that way).
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#40507 - 11/04/02 05:22 PM Re: open-end consumer credit disclosures
OnTheEdge Offline
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If I'm not mistaken the billing rights portion may be included with the periodic stmt or annually.
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#40508 - 11/04/02 05:44 PM Re: open-end consumer credit disclosures
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
You are correct that's why I put in () (other than the annual billing rights notice if you choose to send it that way).
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#40509 - 11/04/02 05:55 PM Re: open-end consumer credit disclosures
OnTheEdge Offline
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SmallTown, USA
Sorry I missed that. That's what happens when I use my "speed reading" talents.
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