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Open-End Credit

Open-End Credit. General Disclosure Requirements. “ Clear and conspicuous ” Written In a form the member can keep. General Disclosure Requirements. What to do about: Unknown Information? Multiple Applicants? Formatting?. Annual Percentage Rate. Periodic Statements Accuracy

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Open-End Credit

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  1. Open-End Credit

  2. General Disclosure Requirements • “Clear and conspicuous” • Written • In a form the member can keep

  3. General Disclosure Requirements What to do about: • Unknown Information? • Multiple Applicants? • Formatting?

  4. Annual Percentage Rate • Periodic Statements • Accuracy • Oral Disclosures

  5. Account Opening disclosures

  6. Account Opening Disclosures Format: • Table • Bolding • No Bolding

  7. Table Contents • APRs • Variable Rate Information • Introductory Rates • Premium Rates • Penalty Rates • Fees for Issuance or Availability • Fixed Finance Charges/Minimum Interest Charge • Transaction Charges • Grace Period • Fees • Website Reference

  8. Below the table • Introductory Rate Information • Employee Preferential Rate Information • Balance Computation Method • Billing Error Rights Reference

  9. Disclosures in the Agreement • Charges imposed as part of the plan • Balance Computation Method • Variable Rate Information • Voluntary Credit Insurance • Security Interests • Statement of Billing Rights

  10. Periodic statements

  11. Periodic Statements • General Rules • Timing

  12. Content • Previous Balance • Identification of Transactions • Credits • Periodic Rates • Balance on Which the Finance Charge is Computed • Charges Imposed • Change-in-Terms • Grace Period • Billing Error Address • Closing Date of Billing Cycle and New Balance • Deferred Interest Disclosure

  13. Statement of Billing Rights • Annual Statement • Alternative Summary Statement

  14. Supplemental Credit Access Devices Disclosures are dependent on: • The account type • The device or feature offered • The time frame in which the device is offered • The offer terms

  15. Change in Terms • Timing • Member Agreement to Change • Required Content • Formatting Requirements • Exceptions • Reductions in the Credit Limit • Rate Increases due to Delinquency or Default

  16. Payments • General Information • Payment Specifications • Non-Conforming Payments • Adjustments • Credit Balances • Account Termination

  17. Billing Errors • Definition • Notice • Time Frame for Resolution • Rules Pending Resolution • Procedures if an Error Occurred • Procedures if an Error Did Not Occur • Duties after Resolution • Re-assertion of a Claim

  18. Multi-Feature Open-Ended Lending Key Concepts: • Existence of a Plan • Repeated Transactions • Reusable Line • Credit Verifications • Verification of Collateral Value

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