Credit Card Change in Terms Format Question

Posted By: Likes to Comply

Credit Card Change in Terms Format Question - 04/05/17 06:39 PM

We want to change the cash advance APR of 18.50 variable to 18.50 fixed. My question is can it be as a statement message like the following -

Important Changes to Your Account Terms
The following is a summary of the changes that are being made to your account terms. All changes are effective 06/01/17.

These changes will impact your account as follows:

Transactions made before, on or after 06/01/17: As of 06/01/17, any changes to APRs described below will apply to these transactions.

Revised Terms, as of 06/01/17
APR for Cash Advances 18.50% (Non-Variable)

or must it be in the tabular format like the model form G-20?

The problem we have is that the statement vendor can put it in the non-tabular format as a statement message that will appear on the first page of the statement as required by 1026.9(iv)(D)(2). But if we do the tabular format it will print as the last page of the statement.

Sorry to ask, but I am having a difficult time making out if the model format must be used or not. If it doesn't have to be in the model form format, then it fixes our problem of ensuring that the change in terms notice is on the first page of the periodic statement.

Thanks in advance.
Posted By: Likes to Comply

Re: Credit Card Change in Terms Format Question - 04/05/17 07:01 PM

Never mind...after reading it 100xs I've finally noticed that tabular format is required and it can be on the front of any page in the periodic statement.