APR 18-font type requirement on purchases, is this applicable to corporate credit cards?
Thanks for your assistance.

What is your cite? At first blush it looks like you are combining business credit with Reg. Z disclosures. Don't gotta.

Our web-site has a tel# to get more information on Corporate credit cards. Once the applicant shows interest, they are mailed a folder that has a sheet for credit card features on a table format, a credit card agreement, corporate resolution, etc.
I am wondering if we need to change the font on APR purchases?

I haven't worked with credit card disclosures in some time, but this is a business credit and not a consumer so you have no Reg. Z worries. Would it a state requirement?

no it is not a state requirement. I think i am not interpreting this right. 226.2(a)(8) reads for purposes of 226.12a and b-Special credit card provisions , the term includes any person whom a credit card is issued for any purpose, including business, commercial .. 226.2(a)(8)

As I look at those definitions I agree. It is using the term "natural person" and "person". The latter being defined to include business entities.

.12(a) and (b) address issuance of the card and liability. Where do you think anything requires an 18 point font?

I'm not sure I can help, but I'll try.

That is what I am struggling with. It does not address anywhere the 18-font type for business credits-for disclosure purposes. I guess it does not apply.

You are asking why you're doing it?

I can say that I searched "Z" for "18" and for "18-font" and I came up with nada. Perhaps this is a "that's the way we've always done it" scenario.

While you can't hide it, it generally has to be clear and conspicuous, not glaring. I remember the grid for disclosures and changes recommended after we sold our portfolio. If it isn't required there in some way, as compared to the rest of your disclosure, you should be OK unless someone else has a cite.

Andy - the 18 point font is in the latest revision to Reg Z and became effective Oct. 1, 2001.

See § 226.5a Credit and charge card applications and solicitations. Specifically, 226.5a (b)(1) Annual percentage rate. Each periodic rate that may be used to compute the finance charge on an outstanding balance for purchases, a cash advance, or a balance transfer, expressed as an annual percentage rate (as determined by § 226.14(b)). When more than one rate applies for a category of transactions, the range of balances to which each rate is applicable shall also be disclosed. The annual percentage rate for purchases disclosed pursuant to this paragraph shall be in at least 18-point type, except for the following: a temporary initial rate that is lower than the rate that will apply after the temporary rate expires, and a penalty rate that will apply upon the occurrence of one or more specific events.

As far as I know, the only part of Reg Z that would apply to business credit is 226.12 which deals with unsolicited issuance of a credit card and liability for unauthorized use. If 10 or more cards are issued for one organization, you may contractually agree on liability for unauthorized use, however the liability may not be posed on an employee either by the issuer or the employer.

So the short answer would be: The 18 point font is required for consumer credit cards. No Reg Z disclosure is required for business credit cards. Or at least, we don't have any Reg Z disclosure for our business credit cards!

This is one area where Reg Z differs from Reg E. Under Reg E, a business account does not have the same protection for errors and unauthorized use. Under Reg Z, they do.

Bonnie is right. To test how I missed that I went and narrowed my search to just that section of the Reg. I asked for a search on "18" (sans quotes) and it gave me zero hits. The search ignored it for some reason. And, as noted, I wasn't reading the regs, just searching on them.

Thanks for the catch. Now I wonder why it missed it, and what else I may have missed. I have some questions to ask. Anyone else using teh CCH have this problem?

Andy, I checked my CCH as well and I got 20 hits on '18' (w/o quotes) but not 225.5a. It's not just you...

Thanks. At least I know it wasn't a case of operator headspace. And thanks again to Bonnie. I'd have felt bad misleading someone like that. A good read of the regs may be in order.