Question:
We are in the process of a compliance exam. We advertise our credit cards on the Internet and have brochures printed that are the same as the Internet. We have disclosed on our advertising page and in our brochures that if the consumer has any of our services they could qualify for a percentage off the credit card rate. The examiners are saying we cannot include the discounts with our advertising of the credit card disclosures under Reg Z. Let me give an example: "Our current annual percentage rate is 15.96%; however, your total relationship with the bank can qualify you for an annual percentage rate as low as 9.96% Based on the following discounts: Checking .84% Direct Dep. .48% Safe dep. box .24 Savings Acct. .48 Home(R/E)loan 1.08%, etc. This is on the Internet page above the required disclosures and is the on back of an insert with the required disclosures for printed applications. Can we not disclose the discounts available if consumers have accounts with us? It is not a requirement to get a credit card to have to have our services. Anyone can apply. The examiner is quoting 226.16(b)(1) and (3) tying to 226.6 (a)