MLA & Comparing Credti Card Fees to Issuers

Posted By: Compliance Poster

MLA & Comparing Credti Card Fees to Issuers - 12/18/19 06:59 PM

The rules on comparing credit card fees to five or more creditors of whose U.S. credit cards is at least $3 billion in an outstanding balance also states “at any time during the three-year period preceding the time such average is computed.”

Will you please help me on the meaning of this phrase as relates to the timing of the comparison? I was under the impression that the comparison should be done on an annual basis. Your advise would be appreciated.