I am reviewing our credit card applications. After reading 226.5a, I think I am more confused than when I started. I read that the disclosures in b 1 -7 (which includes the APR)must be clear and conspicuous, which is defined as usually 12 point in the commentary. Then I read in 226.5a (b)(1), that the APR should be in 18 point type.

Should I take this to mean that all disclosures should be in 12 point type, except the APR, which should be 18? Or does the APR just have to be more conspicuous than the other disclosures?

Thanks in advance!

Your disclosures can be from 8 point to 12 point. Most disclosures that I've seen are between 10 and 12.

The APR must be 18 point for the disclosure table.

Thanks, that's what I thought. It's just nice to get validation from someone else!!