Unfair or Deceptive Acts or Practices; Clarifications, 20804-20832 [E9-9861]
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20804
Federal Register / Vol. 74, No. 85 / Tuesday, May 5, 2009 / Proposed Rules
FEDERAL RESERVE SYSTEM
12 CFR Part 227
[Regulation AA; Docket No. R–1314]
DEPARTMENT OF THE TREASURY
Office of Thrift Supervision
12 CFR Part 535
[Docket ID OTS–2009–0006]
RIN 1550–AC17
NATIONAL CREDIT UNION
ADMINISTRATION
12 CFR Part 706
RIN 3133–AD62
Unfair or Deceptive Acts or Practices;
Clarifications
AGENCIES: Board of Governors of the
Federal Reserve System (Board); Office
of Thrift Supervision, Treasury (OTS);
and National Credit Union
Administration (NCUA).
ACTION: Proposed rule; request for
public comment.
SUMMARY: In December 2008, the Board,
OTS, and NCUA (collectively, the
Agencies) exercised their authority
under the Federal Trade Commission
Act to issue a final rule prohibiting
institutions from engaging in specific
acts or practices in connection with
consumer credit card accounts. The
Agencies understand that clarification is
needed regarding certain aspects of the
final rule. Accordingly, in order to
facilitate compliance, the Agencies
propose to amend specific portions of
the regulations and official staff
commentary.
DATES: Comments must be received on
or before June 4, 2009.
ADDRESSES: Because paper mail in the
Washington DC area and at the Agencies
is subject to delay, we encourage
commenters to submit comments by
e-mail, if possible. We also encourage
commenters to use the title ‘‘Unfair or
Deceptive Acts or Practices’’ to facilitate
our organization and distribution of the
comments. Comments submitted to one
or more of the Agencies will be made
available to all of the Agencies.
Interested parties are invited to submit
comments as follows:
Board: You may submit comments,
identified by Docket No. R–1314, by any
of the following methods:
• Agency Web site: https://
www.federalreserve.gov. Follow the
instructions for submitting comments at
https://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.cfm.
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• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• E-mail:
regs.comments@federalreserve.gov.
Include the docket number in the
subject line of the message.
• Facsimile: (202) 452–3819 or (202)
452–3102.
• Mail: Jennifer J. Johnson, Secretary,
Board of Governors of the Federal
Reserve System, 20th Street and
Constitution Avenue, NW., Washington,
DC 20551.
All public comments are available
from the Board’s Web site at https://
www.federalreserve.gov/generalinfo/
foia/ProposedRegs.cfm as submitted,
unless modified for technical reasons.
Accordingly, your comments will not be
edited to remove any identifying or
contact information. Public comments
may also be viewed electronically or in
paper form in Room MP–500 of the
Board’s Martin Building (20th and C
Streets, NW.), between 9 a.m. and 5 p.m.
on weekdays.
OTS: You may submit comments,
identified by OTS–2009–0006, by any of
the following methods:
• Federal eRulemaking Portal‘‘Regulations.gov’’: Go to https://
www.regulations.gov, under the ‘‘more
Search Options’’ tab click next to the
‘‘Advanced Docket Search’’ option
where indicated, select ‘‘Office of Thrift
Supervision’’ from the agency dropdown menu, then click ‘‘Submit.’’ In the
‘‘Docket ID’’ column, select ‘‘OTS–
2009–0006’’ to submit or view public
comments and to view supporting and
related materials for this proposed
rulemaking. The ‘‘How to Use This Site’’
link on the Regulations.gov home page
provides information on using
Regulations.gov, including instructions
for submitting or viewing public
comments, viewing other supporting
and related materials, and viewing the
docket after the close of the comment
period.
• Mail: Regulation Comments, Chief
Counsel’s Office, Office of Thrift
Supervision, 1700 G Street, NW.,
Washington, DC 20552, Attention: OTS–
2009–0006.
• Facsimile: (202) 906–6518.
• Hand Delivery/Courier: Guard’s
Desk, East Lobby Entrance, 1700 G
Street, NW., from 9 a.m. to 4 p.m. on
business days, Attention: Regulation
Comments, Chief Counsel’s Office,
Attention: OTS–2009–0006.
• Instructions: All submissions
received must include the agency name
and docket number for this rulemaking.
All comments received will be entered
into the docket and posted on
Regulations.gov without change,
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including any personal information
provided. Comments, including
attachments and other supporting
materials received are part of the public
record and subject to public disclosure.
Do not enclose any information in your
comment or supporting materials that
you consider confidential or
inappropriate for public disclosure.
• Viewing Comments Electronically:
Go to https://www.regulations.gov, select
‘‘Office of Thrift Supervision’’ from the
agency drop-down menu, then click
‘‘Submit.’’ Select Docket ID ‘‘OTS–
2009–0006’’ to view public comments
for this notice of proposed rulemaking.
• Viewing Comments On-Site: You
may inspect comments at the Public
Reading Room, 1700 G Street, NW., by
appointment. To make an appointment
for access, call (202) 906–5922, send an
e-mail to public.info@ots.treas.gov, or
send a facsimile transmission to (202)
906–6518. (Prior notice identifying the
materials you will be requesting will
assist us in serving you.) We schedule
appointments on business days between
10 a.m. and 4 p.m. In most cases,
appointments will be available the next
business day following the date we
receive a request.
NCUA: You may submit comments,
identified by number RIN 3133–AD62,
by any of the following methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• NCUA Web site: https://
www.ncua.gov/news/proposed_regs/
proposed_regs.html. Follow the
instructions for submitting comments.
• E-mail: Address to
regcomments@ncua.gov. Include ‘‘[Your
name] Comments on Proposed Rule Part
706’’ in the e-mail subject line.
• Facsimile: (703) 518–6319. Use the
subject line described above for e-mail.
• Mail: Address to Mary Rupp,
Secretary of the Board, National Credit
Union Administration, 1775 Duke
Street, Alexandria, VA 22314–3428.
• Hand Delivery/Courier: Same as
mail address.
• Public Inspection: All public
comments are available on the agency’s
Web site at https://www.ncua.gov/
RegulationsOpinionsLaws/comments as
submitted, except as may not be
possible for technical reasons. Public
comments will not be edited to remove
any identifying or contact information.
Paper copies of comments may be
inspected in NCUA’s law library at 1775
Duke Street, Alexandria, Virginia 22314,
by appointment, weekdays between 9
a.m. and 3 p.m. To make an
appointment, call (703) 518–6540 or
send an e-mail to OGCMail@ncua.gov.
FOR FURTHER INFORMATION CONTACT:
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Federal Register / Vol. 74, No. 85 / Tuesday, May 5, 2009 / Proposed Rules
Board: Benjamin K. Olson, Attorney,
or Ky Tran-Trong, Counsel, Division of
Consumer and Community Affairs, at
(202) 452–2412 or (202) 452–3667,
Board of Governors of the Federal
Reserve System, 20th and C Streets,
NW., Washington, DC 20551. For users
of Telecommunications Device for the
Deaf (TDD) only, contact (202) 263–
4869.
OTS: April Breslaw, Director,
Consumer Regulations, (202) 906–6989;
Suzanne McQueen, Consumer
Regulations Analyst, Compliance and
Consumer Protection Division, (202)
906–6459; or Richard Bennett, Senior
Compliance Counsel, Regulations and
Legislation Division, (202) 906–7409, at
Office of Thrift Supervision, 1700 G
Street, NW., Washington, DC 20552.
NCUA: Matthew J. Biliouris, Program
Officer, Office of Examination and
Insurance, (703) 518–6360; or Moisette
I. Green, Staff Attorney, Office of
General Counsel, (703) 518–6540,
National Credit Union Administration,
1775 Duke Street, Alexandria, VA
22314–3428.
SUPPLEMENTARY INFORMATION:
I. Background
In December 2008, the Federal
Reserve Board (Board), the Office of
Thrift Supervision (OTS), and the
National Credit Union Administration
(NCUA) (collectively, the Agencies)
adopted a final rule under the Federal
Trade Commission Act (FTC Act) to
protect consumers from unfair acts or
practices with respect to consumer
credit card accounts. This rule was
published in the Federal Register on
January 29, 2009. See 74 FR 5498
(January 2009 Rule). On that same date,
the Board published a final rule
amending the provisions regarding
open-end credit (not home secured) in
Regulation Z, which implements the
Truth in Lending Act (TILA). See 74 FR
5244 (January 2009 Regulation Z Rule).
The effective date for both rules is July
1, 2010. See 74 FR 5548; 74 FR 5388–
5390.
Since publication of the two rules, the
Agencies have become aware that
clarification is needed to resolve
confusion regarding how institutions
will comply with particular aspects of
those rules. Accordingly, in order to
provide guidance and facilitate
compliance with the January 2009 Rule
by the effective date, the Agencies
propose to amend portions of the rule
and the accompanying staff
commentary. These proposed
amendments are discussed in detail in
section III of this SUPPLEMENTARY
INFORMATION. Similarly, elsewhere in
today’s Federal Register, the Board has
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proposed to amend certain aspects of
the January 2009 Regulation Z Rule.
Although comment is requested on
the proposed amendments, the Agencies
emphasize that the purpose of these
rulemakings is to clarify and facilitate
compliance with the final rule, not to
reconsider the need for—or the extent
of—the protections that the rule affords
consumers. Thus, commenters are
encouraged to limit their submissions
accordingly.
In addition, because the Agencies do
not intend to extend the effective date
for the January 2009 Rule, any
amendments must be adopted in final
form with sufficient time for institutions
to implement the amended rule on or
prior to July 1, 2010. The Agencies
emphasize that, because this rulemaking
focuses on clarifications to discrete
aspects of the January 2009 Rule,
institutions should continue their efforts
to come into compliance with that rule
as soon as practicable and, in any event,
prior to July 1, 2010. In order to ensure
that final clarifications can be provided
as soon as possible, the Agencies are
requiring that comments on this
proposal be submitted within 30 days
from publication in the Federal
Register.1
II. Statutory Authority
Section 18(f)(1) of the FTC Act
provides that the Board (with respect to
banks), OTS (with respect to savings
associations), and the NCUA (with
respect to federal credit unions) are
responsible for prescribing ‘‘regulations
defining with specificity * * * unfair or
deceptive acts or practices, and
containing requirements prescribed for
the purpose of preventing such acts or
practices.’’ 15 U.S.C. 57a(f)(1). In the
SUPPLEMENTARY INFORMATION for the
January 2009 Rule, the Agencies set
forth the standards codified by Congress
or adopted by the Federal Trade
Commission for determining whether an
act or practice is unfair or deceptive and
applied those standards to the practices
prohibited by the final rule. See 74 FR
5501 et seq. In addition, the OTS relied
on its authority under the Home
Owners’ Loan Act (HOLA) as a
secondary basis for its final rule. See,
e.g., 74 FR 5505–5506. For purposes of
this rulemaking, the Agencies continue
to rely on this legal authority and
analysis.
1 Generally, NCUA gives the public 60 days to
comment on proposed rules; however, a shorter
comment period is appropriate in this instance to
ensure compliance with the January 2009 Rule. See
IRPS 87–2, 52 FR 35231 (Sept. 18, 1987).
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III. Section-by-Section Analysis
The final rules adopted by the Board,
OTS, and NCUA under the FTC Act are
located in, respectively, parts 227, 535,
and 706 of title 12 of the Code of
Federal Regulations. For purposes of the
discussion in this SUPPLEMENTARY
INFORMATION, the Agencies use the
shared numerical suffix for each
provision. For example, § l.21 refers to
the Board’s 12 CFR 227.21, the OTS’s 12
CFR 535.21, and the NCUA’s 12 CFR
706.21.
Section l.21—Definitions
Subpart C to the Agencies’ rules
contains the provisions addressing
consumer credit card accounts. Section
l.21 defines certain terms used in
Subpart C.
Section l.21(a)
Rate
Annual Percentage
Section l.21(a) defines ‘‘annual
percentage rate’’ as the product of
multiplying each periodic rate for a
balance or transaction on a consumer
credit card account by the number of
periods in a year. In the text of the
regulations and in the commentary, the
Agencies sometimes use the term ‘‘rate’’
in place of ‘‘annual percentage rate’’ to
conserve space and avoid repetition. To
avoid possible confusion, the Agencies
propose to add a new comment 21(a)–
1, clarifying that, for purposes of
Subpart C, ‘‘rate’’ has the same meaning
as ‘‘annual percentage rate’’ unless
otherwise specified. Furthermore, for
clarity and consistency, the Agencies
propose to substitute ‘‘rate’’ for ‘‘annual
percentage rate’’ in the titles to certain
comments. See comments 23–3, 23–6,
24(b)(2)–5, 24(b)(5)–2, 24(c)(1)(i)–2.
Section l.21(c)
Account
Consumer Credit Card
The provisions of Subpart C apply to
‘‘consumer credit card accounts,’’ which
are defined in § l.21(c) as accounts
provided to a consumer primarily for
personal, family, or household purposes
under an open-end credit plan that is
accessed by a credit or charge card.
Based on questions received following
issuance of the January 2009 Rule, the
Agencies understand that clarification is
needed regarding whether an
outstanding balance on a consumer
credit card account remains subject to
Subpart C when the account is closed,
when the account is acquired by another
institution, and when the balance is
transferred to another credit account. In
particular, concerns have been raised
that permitting institutions to apply an
increased rate to an outstanding balance
in these circumstances could lead to
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circumvention of the general
prohibition in § l.24 on such increases.
To address these concerns, the
Agencies propose to add comments
21(c)–1 through 3, which would clarify
that, as a general matter, the protections
in Subpart C continue to apply to an
outstanding balance following the
closure or acquisition of the account or
the transfer of the balance to another
credit account issued by the same
institution (or its affiliate or subsidiary).
Accordingly, in these circumstances, an
institution must, for example, continue
to provide consumers a reasonable
amount of time to make payment on
such balances pursuant to § l.22;
allocate payments in excess of the
required minimum periodic payment
among such balances consistent with
§ l.23; and increase the annual
percentage rates that apply to such
balances only to the extent permitted by
§ l.24.
Because the protections in Subpart C
cannot be waived or forfeited, the
proposed comments do not distinguish
between closures or transfers initiated
by the institution and closures or
transfers initiated by the consumer. In
the January 2009 Rule, the Agencies
determined that, because many of the
prohibited practices cannot be
effectively disclosed, consumers are
unable to reasonably avoid the harm
caused by those practices. Thus, as
discussed below, allowing institutions
to engage in the prohibited practices by
obtaining the consumer’s agreement
could undercut the purpose of the rule.
Although there may be circumstances
in which individual consumers could
make informed choices about the
benefits and costs of waiving the
protections in Subpart C, an exception
for those circumstances would create a
significant loophole that could be used
to deny the protections to other
consumers. For example, if an
institution offered to transfer its
cardholder’s outstanding balance to a
credit product that would reduce the
rate on the balance for a period of time
in exchange for the cardholder
accepting a higher rate after that period,
the cardholder would have to determine
whether the savings created by the
temporary reduction would offset the
cost of the subsequent increase, which
would depend on the amount of the
balance, the amount and length of the
reduction, the amount of the increase,
and the length of time it would take the
consumer to pay off the balance at the
increased rate. Based on extensive
consumer testing conducted during the
preparation of the January 2009 Rule
(and the Board’s January 2009
Regulation Z Rule), the Agencies believe
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that it would be very difficult to ensure
that institutions disclose this
information in a manner that will enable
most consumers to make informed
decisions about whether to accept the
increase in rate. Although some
approaches to disclosure may be
effective, others may not and it would
be impossible to distinguish among
such approaches in a way that would
provide clear guidance for institutions.
Furthermore, consumers might be
presented with choices that are not
meaningful (such as a choice between
accepting a higher rate on an
outstanding balance or losing credit
privileges on the account). Thus, the
proposed commentary to § l.21(c)
would clarify that, as a general matter,
the protections in Subpart C do not
depend on whether the consumer agrees
to the closure of an account or the
transfer of a balance.
Accordingly, proposed comment
21(c)–1 states that, if a consumer credit
card account with an outstanding
balance is closed by the consumer or the
institution, the account continues to be
the same consumer credit card account
for purposes of Subpart C with respect
to that balance. Thus, in these
circumstances, the institution could not
increase the rate that applies to the
outstanding balance (except to the
extent permitted by § l.24).
Proposed comment 21(c)–2 addresses
circumstances in which an institution
acquires a consumer credit card account
with an outstanding balance by, for
example, merging with or acquiring
another institution or by purchasing
another institution’s credit card
portfolio. In some cases, the acquiring
institution may elect to close the
acquired account and replace it with its
own credit card account. See 12 CFR
226.12 comment 12(a)(2)–3. The
acquisition of an account does not
involve any choice on the part of
consumers, and the Agencies believe
that consumers whose accounts are
acquired should receive the same level
of protection after acquisition as they
did beforehand. Accordingly, the
proposed comment states that an
institution that acquires a consumer
credit card account remains subject to
the provisions of Subpart C with respect
to any outstanding balances on the
account. For example, the institution
would generally be prohibited from
increasing the annual percentage rate on
an outstanding purchase balance to the
rate that the institution applies to
purchases on its accounts.2
2 Thus, the acquiring institution would not be
permitted to substitute a new index for the index
applicable to an acquired variable rate balance if the
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Finally, proposed comment 21(c)–3
addresses balance transfers between
accounts issued by the same institution
(or its affiliate or subsidiary) and
balance transfers between accounts
issued by different institutions.
Balances may be transferred from one
consumer credit card account issued by
an institution to another consumer
credit card account issued by the same
institution when, for example, the
consumer’s account is converted from a
retail credit card that may only be used
at a single retailer or affiliated group of
retailers to a co-branded general
purpose credit card which may be used
at a wider number of merchants.
Because of the concerns discussed
above regarding circumvention and
informed consumer choice and for
consistency with the issuance rules
regarding card renewals or substitutions
for accepted credit cards under
Regulation Z, 12 CFR 226.12(a)(2), the
Agencies believe—and proposed
comment 21(c)–3 states—that these
transfers should be treated as a
continuation of the existing account
relationship rather than the creation of
a new account relationship. See 12 CFR
226.12 comment 12(a)(2)–2. Similarly,
proposed comment 21(c)–3 would apply
to circumstances where a balance is
transferred to a line of credit accessed
solely by an account number or another
type of credit account issued by the
same institution or its affiliate or
subsidiary (except for an open-end
credit plan secured by the consumer’s
dwelling).3 Accordingly, under these
circumstances, an institution could not,
for example, apply an increased rate to
an existing balance in a manner
prohibited by § l.24.
In contrast, proposed comment 21(c)–
3 also states that, when a consumer
chooses to transfer a balance to a
consumer credit card account issued by
a different institution, Subpart C does
not prohibit the institution to which the
balance is transferred from applying its
change could result in an increase in the applicable
annual percentage rate. See comment 24(b)(2)–1. An
institution that does not utilize the index used to
determine the variable rate for an acquired balance
may, however, convert that rate to an equal or lower
non-variable rate, subject to the notice requirements
of 12 CFR 226.9(c). See comment 24(b)(2)–5.
3 Proposed comment 21(c)–3 clarifies that Subpart
C would not apply to balances transferred from a
consumer credit card account issued by an
institution to an open-end credit plan secured by
the consumer’s dwelling issued by the same
institution (or its affiliate or subsidiary) because
these plans provide protections that are similar to—
and, in some cases, more stringent than—the
protections in Subpart C. For example, a creditor
may not change the annual percentage rate on a
home-equity plan unless the change is based on an
index that is not under the creditor’s control and
is available to the general public. See 12 CFR
226.5a(f)(1).
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account terms to that balance, provided
those terms comply with Subpart C. For
example, if a consumer credit card
account issued by institution A has a
$1,000 purchase balance at an annual
percentage rate of 15% and the
consumer transfers that balance to a
consumer credit card account with a
purchase rate of 17% issued by
institution B, institution B may apply
the 17% rate to the $1,000 balance.
However, institution B may not
subsequently increase the rate that
applies to that balance unless permitted
by one of the exceptions in § l.24(b).
Although balance transfers from one
institution to another raise some of the
same concerns as balance transfers
involving the same institution, the
Agencies believe that transfers between
institutions are not contrary to Subpart
C because the institution to which the
balance is transferred is not increasing
the cost of credit it previously extended
to the consumer. For example, assume
that institution A has extended a
consumer $1,000 of credit at a rate of
15%. Because § l.24 generally
prohibits institution A from increasing
the rate that applies to that balance, it
would be inconsistent with § l.24 to
allow institution A to reprice that
balance simply by transferring it to
another account. In contrast, in order for
the $1,000 balance to be transferred to
institution B, institution B must provide
the consumer with a new $1,000
extension of credit in an arms-length
transaction and should be permitted to
price that new extension consistent with
its evaluation of prevailing market rates,
the risk presented by the consumer, and
other factors. Thus, the transfer from
institution A to institution B does not
appear to raise concerns about
circumvention of § l.24 because
institution B is not increasing the cost
of credit it previously extended.
The Agencies understand that
drawing this distinction between
balance transfers involving the same
institution and balance transfers
involving different institutions may
limit an institution’s ability to offer its
existing cardholders the same terms that
it would offer another institution’s
cardholders. Currently, however, the
Agencies understand that institutions
generally do not make promotional
balance transfer offers available to their
existing cardholders for balances held
by the institution because it is not costeffective to do so. Furthermore,
although many institutions do offer
existing cardholders the opportunity to
upgrade to accounts offering different
terms or features (such as upgrading to
an account that offers a particular type
of rewards), the Agencies understand
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that these offers generally are not
conditioned on a balance transfer,
which indicates that it may be costeffective for institutions to make these
offers without repricing an outstanding
balance. Nevertheless, the Agencies
solicit comment on the extent to which
proposed comment 21(c)–3 would affect
institutions’ ability to make offers to
existing cardholders.
Section l.22—Unfair Acts or Practices
Regarding Time To Make Payment
Section l.22(a) provides that an
institution must not treat a payment on
a consumer credit card account as late
for any purpose unless the consumer
has been provided a reasonable amount
of time to make the payment. Section
l.22(b)(1) states that an institution
must be able to demonstrate that it has
complied with this requirement, and
§ l.22(b)(2) provides a safe harbor for
institutions that have adopted
reasonable procedures designed to
ensure that periodic statements
specifying the payment due date are
mailed or delivered to consumers at
least 21 days before the payment due
date.
Comment 22(b)–3 offers an example
of an alternative method of complying
with § l.22(a). In this example, an
institution that only provides periodic
statements electronically and only
accepts payments electronically for a
particular type of consumer credit card
account could comply with § l.22(a)
even if it does not provide periodic
statements 21 days before the payment
due date. The Agencies understand that,
although the example states that this
type of account must also comply with
‘‘applicable law and regulatory
guidance,’’ an explicit reference to the
consumer notice and consent
procedures of the Electronic Signatures
in Global and National Commerce Act
(E-Sign Act), 15 U.S.C. 7001 et seq., may
be helpful to avoid confusion.
Accordingly, the Agencies propose to
add an explicit reference to the E-Sign
Act in comment 22(b)–3.
Section l.23—Unfair Acts or Practices
Regarding Allocation of Payments
When different annual percentage
rates apply to different balances on a
consumer credit card account, § l.23
requires institutions to allocate any
amount paid by the consumer in excess
of the required minimum periodic
payment (the excess payment) among
the balances using one of two methods.
The institution may apply the excess
payment first to the balance with the
highest annual percentage rate and any
remaining portion to the other balances
in descending order based on the
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applicable rate (the high-to-low
method). Alternatively, the institution
may allocate the excess payment among
the balances in the same proportion as
each balance bears to the total balance
(the pro rata method).
When the Agencies originally
proposed to address payment allocation,
the proposed rule contained provisions
specifically addressing accounts with a
balance subject to a deferred interest
program.4 One of these proposed
provisions would have permitted (but
not required) an existing practice by
some institutions of allocating excess
payments first to a balance on which
interest is deferred during the last two
billing cycles of the deferred interest
period so that consumers could pay off
that balance and avoid assessment of the
accrued interest. See proposed
§ l.23(b)(1)(ii), 73 FR 28916, 28942
(May 19, 2008). Some industry
commenters supported this aspect of the
proposal, while others argued that it
would require burdensome changes to
their systems. Some consumer group
commenters argued that, rather than
allowing institutions to choose whether
to apply excess payments to deferred
interest balances in the last two billing
cycles, this allocation method should be
mandatory. Due to other concerns about
deferred interest plans, however, the
January 2009 Rule did not include this
provision. See 74 FR 5519, 5527–5528.
As discussed in greater detail below
with respect to § l.24, the Agencies
propose to clarify that—so long as
consumers receive sufficient
protections—institutions may continue
to provide promotional programs under
which a consumer will not be obligated
to pay interest that accrues on a balance
if that balance is paid in full prior to a
specified date or expiration of a
specified period of time (deferred or
waived interest programs).5 One area in
which clarification is needed with
respect to such programs is payment
allocation. Under the current version of
§ l.23, if the deferred or waived
interest balance is not the only balance
on the account, the consumer would
generally be required to pay off the
entire outstanding balance in order to
avoid interest charges on the deferred or
4 Many creditors offer deferred interest programs
under which consumers are not obligated to pay
interest on purchases if those purchases are paid in
full by the end of a specified period. If the
purchases are not paid in full when the period
ends, these programs generally require the
consumer to pay interest that has accrued on the
purchases during the period.
5 For purposes of this SUPPLEMENTARY
INFORMATION, a waived interest program includes a
promotional program where interest is refunded if
a balance is paid in full within a specified period
of time.
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waived interest balance.6 If the
consumer is unaware of the need to pay
off the entire balance, the consumer
would be charged interest on the
deferred or waived interest balance and
thus would not obtain the benefits of the
promotional program.
To ensure that consumers are
adequately protected, the Agencies
propose to amend § l.23 to require
institutions to allocate excess payments
first to deferred or waived interest
balances during the last two billing
cycles of the promotional period. As
noted above, this is consistent with the
current practice of many institutions
with respect to deferred interest plans
and is generally beneficial to consumers
insofar as it enables them to avoid
interest charges by paying off the
accrued interest balance in full prior to
expiration without paying off all other
balances on the account.7 Accordingly,
the Agencies propose to move the
provisions in the current version of
§ l.23 to § l.23(a), to place the new
provision for deferred or waived
programs in § l.23(b), and to renumber
the existing commentary accordingly.
The Agencies also propose to add a new
example in comment 23(a)–1 (proposed
6 For example, assume that a consumer credit
card account has a $2,000 purchase balance with a
20% annual percentage rate and a $1,000 balance
on which interest accrues at a 15% annual
percentage rate, but the consumer will not be
obligated to pay that interest if that balance is paid
in full by a specified date. Regardless of whether
the institution uses the high-to-low allocation
method or the pro rata allocation method, the
consumer would be required to pay $3,000 in order
to avoid interest charges on the $1,000 balance.
Indeed, under the current version of § l.23, the
only circumstance in which the consumer could
pay off the $1,000 balance without also paying off
the $2,000 purchase balance would be if the $1,000
balance had a higher annual percentage rate than
the $2,000 purchase balance and the institution
chose to use the high-to-low method.
7 As discussed above, for purposes of this
proposal, the Agencies continue to rely on the legal
authority and analysis contained in the January
2009 Rule. In particular, with respect to the
proposed amendment to § l.23, the Agencies rely
on the legal analysis regarding unfair payment
allocation practices at 74 FR 5514–5517. In
addition, the Agencies note that failing to allocate
excess payments first to deferred or waived interest
balances during the last two billing cycles of the
promotional period appears to cause substantial
consumer injury insofar as a different allocation
method would result in the assessment of accrued
interest (unless the consumer pays off all balances
on the account). Because one of the intended
purposes of a credit card account is to finance
purchases over multiple billing cycles, it would be
unreasonable to expect consumers to avoid accrued
interest charges on a deferred or waived interest
balance by paying off all balances on the account.
Finally, failing to comply with the proposed
amendment does not appear to create any benefits
for consumers that would outweigh the injury.
Indeed, the Agencies understand that the payment
allocation practices of many institutions offering
deferred or waived interest programs already
comply with the proposed amendment.
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comment 23(a)(1)–1) illustrating the
application of proposed § l.23(b). In
addition, elsewhere in today’s Federal
Register, the Board has proposed to
amend the disclosure requirements for
periodic statements in Regulation Z, 12
CFR 226.7, to ensure that consumers are
informed of the amount of interest
accrued on the deferred or waived
balance and the date by which that
balance must be paid in full to avoid
those accrued interest charges.8
Furthermore, the Agencies propose to
amend comment 23–6 to clarify that, for
purposes of § l.23, a balance on which
interest will not be charged if the
balance is paid in full prior to
expiration of a specified period should
be treated as a balance with an annual
percentage rate of zero rather than a
balance with the rate at which interest
accrues during the promotional period
(the accrual rate). As an initial matter,
treating the rate as zero is consistent
with the nature of the deferred or
waived interest program insofar as the
consumer will not be obligated to pay
any accrued interest if the balance is
paid in full prior to expiration. In
addition, because § l.23 only applies
when different annual percentage rates
apply to different balances on the
account, using the accrual rate for
purposes of § l.23 could significantly
narrow the protections of the payment
allocation rules. Specifically, when the
accrual rate for a deferred or waived
interest balance is the same as the rate
that applies to purchases (which the
Agencies understand is often the case)
and there are no other balances on the
account, § l.23 would not apply if the
accrual rate was used. For example, if
an account has a $1,000 purchase
balance with an annual percentage rate
of 15% and a $2,000 balance on which
interest accrues at 15% but will not be
charged if that balance is paid in full
within a specific period of time, § l.23
would not apply if the accrual rate of
15% was the applicable rate for the
$2,000 balance for purposes of payment
allocation. The Agencies believe that, in
these circumstances, consumers should
be afforded the protections in § l.23
8 Specifically, the Board is proposing to amend 12
CFR 226.7 comment 7(b)–1 to require creditors
offering deferred or waived interest programs to
disclose on the periodic statement the balance
subject to the program and the amount of interest
that has accrued on that balance. In addition, the
Board is proposing to add a new 12 CFR
226.7(b)(14) that would require creditors to state on
the front of the periodic statement for the two
billing cycles immediately preceding expiration of
the promotional period the date on which the
period expires and that the deferred or waived
interest balance must be paid in full by a specific
date in order to avoid accrued interest charges.
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(and, in particular, the protections in
proposed § l.23(b)).
In addition, for purposes of the highto-low allocation method in
§ l.23(a)(1), treating the rate on this
type of promotional balance as zero
during the accrued interest period
ensures that excess payments will be
applied first to balances on which
interest is being charged, which will
generally result in lower interest charges
if the consumer pays the deferred or
waived interest balance in full prior to
expiration of the promotional period.
Thus, using the above example, the
amendments to comment 23–6 would
clarify that an institution using the highto-low method would allocate excess
payments to the $1,000 purchase
balance before the $2,000 balance until
the last two billing cycles of the accrued
interest period (when proposed
§ l.24(b) would require that excess
payments be applied first to any
remaining portion of the $2,000
balance). Although treating the rate on
the deferred or waived interest balance
as zero could prevent consumers who
wish to pay off that balance in
installments over the course of the
promotional period from doing so, the
Agencies believe that, on balance, this
treatment produces the best overall
outcome for consumers when the highto-low allocation method is used.9
Finally, proposed comment 23(b)–1
would clarify that § l.23(b) applies to
promotional programs under which the
consumer is not obligated to pay interest
that accrues on a balance if that balance
is paid in full prior to the expiration of
a specified period of time, not to grace
periods offered by the institution.
Requests for Comment
The Agencies request comment on:
• Whether the provision in proposed
§ l.23(b) regarding balances on which
interest will not be charged if the
balance is paid in full by a specified
date should apply during the last two
billing cycles of the deferred or waived
interest period or during a longer or
shorter time period.
• Whether proposed § l.23(b) should
apply to a grace period offered by the
institution. In particular, the Agencies
request comment on whether
institutions offer grace periods that only
require consumers to pay certain
balances in full each billing cycle
(rather than the entire balance) and, if
so, whether proposed § l.23(b) should
9 The Agencies note that, if the institution uses
the pro rata allocation method, a proportionate
amount of the excess payment will be applied to
the deferred or waived interest balance each month
during the promotional period.
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permit institutions to apply excess
payments to those balances first.
Section l.24—Unfair Acts or Practices
Regarding Increases in Annual
Percentage Rates
Section l.24(a) requires institutions
to disclose, at account opening, the
annual percentage rates that will apply
to each category of transactions on a
consumer credit card account. In
addition, § l.24(a) prohibits
institutions from increasing those rates
unless specifically permitted by one of
the exceptions in § l.24(b).
As an initial matter, the Agencies
understand that clarification is needed
regarding the meaning of ‘‘category of
transactions’’ for purposes of § l.24.
Accordingly, the Agencies propose to
add a new comment 24–3 to clarify that,
for purposes of § l.24, a ‘‘category of
transactions’’ is a type or group of
transactions to which an annual
percentage rate applies that is different
than the annual percentage rate that
applies to other transactions. For
example, purchase transactions, cash
advance transactions, and balance
transfer transactions are separate
categories of transactions for purposes
of § l.24 if an institution applies
different annual percentage rates to
each. Furthermore, if, for example, the
institution applies different annual
percentage rates to different types of
purchase transactions (such as one rate
for purchases of gasoline and a different
rate for all other purchases), each type
constitutes a separate category of
transactions for purposes of § l.24.10
In addition, the Agencies understand
there is some confusion regarding
whether certain changes to a consumer
credit card account constitute an
‘‘account opening’’ for purposes of
§ l.24 generally and, in particular, the
general prohibition on increasing rates
during the first year after account
opening. Accordingly, the Agencies
propose to add a new comment 24–4
clarifying that, when a consumer has a
credit card account with an institution
and the consumer opens a new credit
card account with the same institution
(or its affiliate or subsidiary), the
opening of the new account constitutes
an ‘‘account opening’’ for purposes of
§ l.24 if the consumer retains the
ability to obtain additional extensions of
credit on both accounts. Thus, for
example, if a consumer opens a credit
card account with an institution on
January 1 of year one and opens a
10 As noted below, the Agencies request comment
on whether institutions establish separate categories
of transactions based on factors other than annual
percentage rates and, if so, for what reasons.
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second credit card account with that
institution on July 1 of year one, the
opening of the second account
constitutes an account opening for
purposes of § l.24 so long as the
consumer can engage in transactions
using either account. This is the case
even if the consumer transfers a balance
from the first account to the second.
Thus, because the institution has two
separate account relationships with the
consumer, the general prohibition in
§ l.24 on increasing rates during the
first year after account opening would
apply to the opening of the second
account.
In contrast, the comment would
clarify that an account has not been
opened for purposes of § l.24 when an
institution replaces one consumer credit
card account with another consumer
credit card account (such as when a
retail credit card is replaced with a
cobranded general purpose card that can
be used at a wider number of
merchants) or when an institution
consolidates or combines a credit card
account with one or more other credit
card accounts into a single credit card
account. As discussed above, the
Agencies believe that these transfers
should be treated as a continuation of
the existing account relationship rather
than the creation of a new account
relationship. Similarly, the comment
would also clarify that the replacement
of an acquired credit card account does
not constitute an ‘‘account opening’’ for
purposes of § l.24. Thus, in these
circumstances, the general prohibition
in § l.24 on increasing rates during the
first year after account opening would
not apply. However, when a
replacement or consolidation occurs
during the first year after account
opening, proposed comment 24–4
would clarify that the institution may
not increase an annual percentage rate
in a manner otherwise prohibited by
§ l.24.11 Similarly, the other
protections in § l.24 (such as the
limitations on repayment of protected
balances in § l.24(c)) would still apply
following the replacement or
consolidation.
Finally, the Agencies understand that
the replacement of one consumer credit
card account with another generally is
11 For example, assume that, on January 1 of year
one, a consumer opens a consumer credit card
account with a purchase rate of 15%. On July 1 of
year one, the account is replaced with a consumer
credit card account issued by the same institution,
which offers different features (such as rewards on
purchases). Under these circumstances, the
institution could not increase the annual percentage
rate for purchases to a rate that is higher than 15%
pursuant to § l.24(b)(3) until January 1 of year two
(which is one year after the first account was
opened).
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20809
not instantaneous. If, for example, a
consumer requests that a credit card
account with a $1,000 balance be
upgraded to a credit card account that
offers rewards on purchases, the second
account may be opened immediately or
within a few days but, for operational
reasons, there may be a delay before the
$1,000 balance can be transferred and
the first account can be closed.12
Accordingly, the Agencies solicit
comment on whether the appropriate
amount of time for the replacement of
one consumer credit card account with
another is 15 days, 30 days, or a
different period.13
Section l.24(a) General Rule
The Agencies also understand that
there is some confusion regarding the
relationship between comment 24(a)–1
and Regulation Z, 12 CFR
226.6(b)(2)(i)(D) with respect to the
disclosure of penalty rates. Specifically,
comment 24(a)–1 states that institutions
cannot satisfy the disclosure
requirements in § l.24(a) by disclosing
a range of annual percentage rates or
that a rate will be ‘‘up to’’ a particular
amount. In contrast, when more than
one penalty rate may apply, 12 CFR
226.6(b)(2)(i)(D) permits creditors to
disclose ‘‘the highest rate that could
apply, instead of disclosing the specific
rates or the range of rates that could
apply.’’ Because the disclosure
requirements in § l.24(a) are intended
to ensure that consumers receive notice
at account opening of the specific
annual percentage rates that will apply
to the categories of transactions on the
account, those requirements do not
apply to rates that may or may not apply
depending on a particular event or
occurrence (such as penalty rates) or
rates that may be applied at the
institution’s discretion. Therefore, the
Agencies propose to amend comment
24(a)–1 accordingly. The Agencies note,
however, that this clarification is
limited to the disclosure requirements
in § l.24(a) and does not alter
§ l.24(a)’s general prohibition on
applying penalty rates or other
contingent rates unless specifically
permitted by § l.24(b).
The Agencies also propose the
following clarifications and technical
corrections to the commentary to
§ l.24(a):
• Amend the example in comment
24(a)–2.i to clarify that the institution
12 As discussed above, the proposed commentary
to § l.21 would clarify that, in these
circumstances, the institution could not increase
the annual percentage rate that applies to the $1,000
balance unless otherwise permitted by § l.24.
13 Proposed comment 24–4 provides 15 days and
30 days as alternatives.
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disclosed a penalty rate at account
opening.
• Amend the example in comment
24(a)–2.iii to clarify that the 12 CFR
226.9(g) notice states that, if the
consumer becomes more than 30 days
late on the account, the penalty rate will
apply to all balances on the account.
• Amend the example in comment
24(a)–2.iii.C to correct a typographical
error.
Section l.24(b)(1) Account Opening
Disclosure Exception
Section l.24(b)(1) provides that an
annual percentage rate for a category of
transactions may be increased to a rate
disclosed at account opening upon
expiration of a period of time disclosed
at account opening. Under this
exception, if, for example, an institution
discloses at account opening that a 5%
rate will apply to purchases for six
months and that a 15% rate will apply
thereafter, the institution can increase
the rate on the existing purchase
balance and on new purchases to 15%
after six months. These plans are
sometimes referred to as ‘‘stepped
rates.’’
Comment 24(b)(1)–1 states that,
because § l.24(b)(1) is limited to
increased rates that will apply after a
specified period of time, the exception
does not permit application of increased
rates that are disclosed at account
opening but are contingent on a
particular event or occurrence or may be
applied at the institution’s discretion.
For example, as illustrated in comment
24(b)(1)–1.i, § l.24(b)(1) does not
permit an institution to apply an
increased penalty rate when a consumer
makes a late payment even if the
institution disclosed that rate at account
opening. For clarity, the Agencies
propose to move this language into the
text of § l.24(b)(1). The Agencies also
propose to amend comment 24(b)(1)–1
to clarify that the examples illustrate the
application of § l.24, rather than just
§ l.24(a).
Comment 24(b)(1)–2 clarifies that
nothing in § l.24 prohibits an
institution from assessing interest due to
the loss of a grace period to the extent
consistent with the prohibition on twocycle billing in § l.25. Because the
Agencies understand that there is some
confusion regarding the relationship
between § l.24 and the provision of a
grace period, the Agencies propose to
add language to this comment clarifying
that an institution has not reduced an
annual percentage rate on a consumer
credit card account for purposes of
§ l.24 if the institution does not charge
interest on a balance when the
consumer pays that balance in full prior
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to the expiration of a grace period. In
addition, for organizational purposes,
the Agencies propose to redesignate this
comment as 24–2 and renumber
comment 24(b)(1)–3 accordingly.
Finally, the Agencies understand that
there is some confusion as to whether
an institution waives the right to impose
an increased rate pursuant to
§ l.24(b)(1) if it does not do so
immediately upon expiration of the
specified time period. As a general
matter, because § l.24 is intended to
increase predictability and transparency
for consumers, the exceptions in
§ l.24(b) do not permit institutions to
retain the right to increase a rate
indefinitely and at their discretion. For
example, if at account opening an
institution discloses a stepped rate of
15% on purchases for one year and 20%
thereafter, the institution can apply a
lower rate of 17% at the end of the year
but, if it wants to retain its right under
§ l.24(b)(1) to apply the 20% rate to
purchases made during the first year, it
must disclose to the consumer (pursuant
to 12 CFR 226.9(c)) how long the 17%
rate will apply and that the 20% rate
will apply thereafter so that the
consumer can make informed decisions
when using the card. See comment
24(b)(1)–3 (proposed comment 24(b)(1)–
2)).
The Agencies understand, however,
that applying an increased rate on a
specific date can present operational
difficulties when that date falls in the
middle of a billing cycle. Accordingly,
to address this concern, the Agencies
propose to add a new comment 24(b)–
1 clarifying that, if § l.24(b) permits an
institution to apply an increased annual
percentage rate on a date that is not the
first day of a billing cycle, the
institution may delay application of the
increased rate until the first day of the
following billing cycle without
relinquishing the ability to apply that
rate.14
Section l.24(b)(3)
Exception
Advance Notice
Section l.24(b)(3) provides that an
annual percentage rate for a category of
transactions may be increased pursuant
to a notice under 12 CFR 226.9(c) or (g)
for transactions that occur more than
seven days after provision of the notice.
The Agencies understand that there has
14 For example, assume that, at account opening
on January 1, an institution discloses that a 10%
rate will apply to purchases for six months and a
15% rate will apply thereafter. The first day of the
billing cycle for the account is the fifteenth of the
month. If the six-month period expires on July 1,
the institution may delay application of the 15%
rate until July 15 without relinquishing its ability
to apply that rate under § l.24(b)(1).
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been some confusion regarding the
interaction between this seven-day
period in § l.24(b)(3) and the
requirement in 12 CFR 226.9(c) and (g)
that notice of an increased rate be
provided at least 45 days prior to
imposition of the increased rate. As
illustrated in the examples in comment
24(b)(3)–3, the distinction is that the
institution may apply the increased rate
to any transaction that occurs after the
seventh day following provision of the
notice, but it must wait 45 days to begin
accruing interest at that rate. The reason
for this distinction is that the two time
periods serve different purposes. The
seven-day period is intended to ensure
that the consumer receives the notice
and is aware of the increased rate before
engaging in transactions to which that
increased rate will eventually apply
(unless the consumer transfers or pays
off the balance). See 74 FR 5531. In
contrast, the 45-day period is intended
to give the consumer sufficient time to
evaluate whether to continue using the
credit card account at the increased rate
or whether better terms can be obtained
elsewhere. See 74 FR 5344–5356. For
additional clarity, the Agencies propose
to amend comment 24(b)(3)–2 to state
that, when calculating interest charges,
§ l.24(b)(3) does not permit an
institution to reach back to days before
the effective date of the rate increase
under 12 CFR 226.9(c) or (g)—in other
words, the date 45 days after provision
of the notice.
The Agencies also propose to amend
comment 24(b)(3)–2 to clarify when a
transaction is deemed to have occurred
for purposes of § l.24(b)(3).
Specifically, the current version of
comment 24(b)(3)–2 states that an
institution may apply a rate increased
pursuant to § l.24(b)(3) to transactions
that are authorized within seven days—
but are settled more than seven days—
after provision of the notice. The
Agencies understand, however, that this
distinction has created some confusion
because, for example, authorization may
not be obtained for all transactions and
because the term ‘‘settled’’ could refer to
different points in the payment process,
including settlement between the
acquirer and the merchant or settlement
between the consumer and the card
issuer. Accordingly, for consistency and
clarity, the Agencies propose to amend
comment 24(b)(3)–2 to clarify that when
a transaction occurred for purposes of
§ l.24(b)(3) is determined by the date of
the transaction (without regard to when
the transaction is authorized, settled, or
posted to the consumer’s account). In
addition, the Agencies would clarify
that, when a merchant places a ‘‘hold’’
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on the available credit on an account for
an estimated transaction amount when
the actual transaction amount will not
be known until a later date, the date of
the transaction for purposes of
§ l.24(b)(3) is the date on which the
merchant determines the actual
transaction amount. The Agencies also
propose to amend the examples in
comment 24(b)(3)–3 for consistency
with these proposed changes.
In addition, the Agencies propose to
amend § l.24(b)(3) and its commentary
to reflect that notice of an increased rate
may be provided under 12 CFR 226.9(b),
which applies to supplemental access
devices (such as convenience checks)
and additional features added to the
account after account opening. 12 CFR
226.9(b) requires creditors to disclose
the rates and other key terms applicable
to the device or feature before the
consumer uses the device or feature for
the first time. For example, 12 CFR
226.9(b)(3)(A) requires that creditors
providing convenience checks to which
a temporary promotional rate applies
disclose key terms on the front of the
page containing the checks, including
the promotional rate, the period during
which the promotional rate will be in
effect, and the rate that will apply after
the promotional rate expires. Thus,
unlike rates increased pursuant to a 12
CFR 226.9(c) and (g) notice, the sevenday period is not necessary for rate
increases disclosed pursuant to 12 CFR
226.9(b) because the device or feature
will not be used before the consumer
has received notice of the applicable
rates and terms. Accordingly, the
Agencies propose to amend § l.24(b)(3)
to provide that increased rates disclosed
pursuant to 12 CFR 226.9(b) must not be
applied to transactions that occurred
prior to provision of the notice. Section
l.24(b)(3) would continue to provide
that increased rates disclosed pursuant
to 12 CFR 226.9(c) or (g) must not be
applied to transactions that occurred
within seven days after provision of the
notice. The Agencies would also clarify
in comment 24(b)(3)–2 that, if a rate
increase is disclosed pursuant to both
12 CFR 226.9(b) and 12 CFR 226.9(c),
that rate may only be applied to
transactions that occur more than seven
days after provision of the 12 CFR
226.9(c) notice. In addition, the
Agencies would add an illustrative
example in new comment 24(b)(3)–4.iv.
Finally, the Agencies understand that
clarification is needed regarding the
application of discounted promotional
rates to existing accounts. As discussed
above, § l.24(b)(1) permits stepped
rates disclosed at account opening. In
addition, comment 24(b)(3)–3 provides
some examples of how a stepped rate
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could be provided pursuant to a 12 CFR
226.9(c) notice. The Agencies did not,
however, specifically address
circumstances in which a discounted
promotional stepped rate is offered after
account opening. Consistent with
comment 24(b)(3)–3, the Agencies
believe that, if the consumer receives
advance notice of the term of the
discounted rate and the rate that will
apply after that term expires, a
promotional stepped rate offer on an
existing account can provide the same
benefits to consumers as a promotional
stepped rate offer at account opening so
long as the offer cannot be used to
increase the rate that applies to preexisting balances.
Accordingly, to clarify that such offers
are permitted, the Agencies propose to
add a new comment 24(b)(3)–4 stating
that nothing in § l.24 prohibits an
institution from lowering the annual
percentage rate that applies to an
existing balance or to new transactions.
The comment would further state,
however, that, if a lower rate is applied
to an existing balance, the institution
cannot subsequently increase the rate on
that balance unless it has provided the
consumer with advance notice of the
increase pursuant to 12 CFR 226.9(b) or
(c). This notice must state the period of
time during which the lower rate will
apply (or the date until which that rate
will apply) and the rate that will apply
after expiration of that period.
Furthermore, to ensure that the
consumer receives notice of the offer
before engaging in transactions that are
subject to that offer (and will therefore
eventually be taken to a higher rate), the
comment would clarify that, when an
institution applies a decreased rate to
transactions that occurred prior to
provision of the notice (or, in the case
of a 12 CFR 226.9(c) or (g) notice,
transactions that occurred within seven
days after provision of the notice), the
institution may not subsequently
increase the rate that applies to those
transactions to a rate that is higher than
the rate that applied prior to the
decrease.15 Finally, the comment would
provide illustrative examples of stepped
rate offers that would comply with these
requirements.16
15 For
example, assume that the annual
percentage rate for purchases on an account is 15%
and that, pursuant to 12 CFR 226.9(c), the
institution provides notice on July 1 that a rate of
5% will apply to purchases until December 31, after
which a rate of 17% will apply. If the institution
applies the 5% rate to purchases made on or before
July 8, the institution may only increase the rate on
those purchases to a maximum of 15% on
December 31.
16 For the same reasons, the Agencies propose to
amend comment 24(b)(1)–3 (proposed comment
24(b)(1)–2) to clarify that institutions may offer
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Section l.24(b)(5) Workout
Arrangement Exception
Section l.24(b)(5) provides that an
annual percentage rate may be increased
due to the consumer’s failure to comply
with the terms of a workout
arrangement between the institution and
the consumer, provided that the annual
percentage rate applicable to a category
of transactions following any such
increase does not exceed the rate that
applied to that category of transactions
prior to commencement of the workout
arrangement. This exception is intended
to encourage institutions to continue
offering workout arrangements that
reduce rates for consumers in serious
default, while also ensuring that a
consumer who enters into such an
arrangement but is unable to comply
with its terms is not charged a rate that
exceeds the rate that applied prior to the
arrangement. See 74 FR 5532.
Because the term ‘‘workout’’ has been
used by the Agencies in other
contexts,17 the Agencies understand
that there is some confusion as to
whether this exception also applies to
temporary hardship arrangements that
assist consumers in overcoming
financial difficulties by lowering the
annual percentage rate for a period of
time. For example, if an account
becomes seriously delinquent because
of a loss of employment, the institution
may reduce the rate that applies to the
outstanding balance from the penalty
rate to a rate of zero on the condition
that the consumer make payments that
will cure the delinquency within a
specified period of time. If the
arrangement is successful, the
institution may choose to return the
annual percentage rate to the rate that
applied prior to commencement of the
temporary hardship arrangement.
Because such arrangements can provide
important benefits to consumers, the
Agencies propose to amend § l.24(b)(5)
and its commentary to clarify that this
exception also applies to temporary
hardship arrangements and when the
consumer completes a workout or
temporary hardship arrangement.
discounted stepped rates during the first year after
account opening so long as the rate that applies
after expiration of the discounted rate does not
exceed the rate disclosed at account opening for
that category of transactions.
17 See, e.g., Board Supervisory Letter SR 03–1 on
Account Management and Loss Allowance
Methodology for Credit Card Lending (Jan. 8, 2003)
(available at https://www.federalreserve.gov/
boarddocs/srletters/2003/sr0301.htm); OTS
Regulatory Bulletin RB 37–16 on Examination
Handbook, Asset Quality Section 218, Credit Card
Lending (May 8, 2006) (available at https://
files.ots.treas.gov/74827.pdf).
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Proposed § l.24(b)(6) Servicemembers
Civil Relief Act Exception
The Agencies understand that
clarification is required regarding the
relationship between § l.24 and certain
provisions of the Servicemembers Civil
Relief Act (SCRA), 50 U.S.C. app. 501 et
seq. Specifically, 50 U.S.C. app.
527(a)(1) provides that ‘‘[a]n obligation
or liability bearing interest at a rate in
excess of 6 percent per year that is
incurred by a servicemember, or the
servicemember and the servicemember’s
spouse jointly, before the
servicemember enters military service
shall not bear interest at a rate in excess
of 6 percent. * * *’’ With respect to
consumer credit card accounts, this
restriction applies during the period of
military service. See 50 U.S.C. app.
527(a)(1)(B).18
Under the current version of § l.24,
an institution that complies with the
SCRA by lowering the rate that applies
to an existing balance on a consumer
credit card account when the consumer
enters military service would not be
permitted to increase the rate for that
balance once the period of military
service ends and the protections of the
SCRA no longer apply. The Agencies
did not intend this result, which
appears to be inconsistent with the
plain language of the SCRA.
Accordingly, the Agencies propose to
add a new exception in § l.24(b)(6)
stating that an annual percentage rate
that has been decreased pursuant to 50
U.S.C. app. 527 may be increased once
that provision no longer applies,
provided that the increased rate does
not exceed the rate that applied prior to
the period of military service.
Treatment of Deferred Interest and
Similar Promotional Programs
In the final rule, the Agencies
concluded that deferred interest
programs, as currently designed and
marketed, are inconsistent with the
general prohibition in § l.24 on the
application of increased rates to existing
balances. See 74 FR 5527–5528. The
Agencies noted that, although such
programs provide substantial benefits to
consumers who pay the balance in full
prior to expiration of the program
(thereby avoiding the assessment of
interest charges), consumers who do not
do so may be unfairly surprised,
particularly because these programs are
typically marketed as ‘‘interest free.’’
Accordingly, the Agencies determined
that the assessment of deferred interest
18 50 U.S.C. app. 527(a)(1)(B) applies to
obligations or liabilities that do not consist of a
mortgage, trust deed, or other security in the nature
of a mortgage.
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is effectively a repricing of past
transactions subject to § l.24 and that
prohibiting this practice would improve
transparency and enable consumers to
make more informed decisions
regarding the cost of using credit. See id.
The Agencies specifically stated,
however, that § l.24 does not prohibit
institutions from offering promotional
programs that provide similar benefits
to consumers but do not raise concerns
about unfair surprise. In particular, the
Agencies noted that an institution could
offer a program where interest is
assessed on purchases at a disclosed
rate for a period of time but the interest
charged is waived if the principal is
paid in full by the end of that period.
The Agencies understand that the
distinction in the January 2009 Rule
between deferred interest and waived
interest has caused confusion with
respect to the manner in which
institutions should structure
promotional programs under which the
consumer will not be obligated to pay
interest that accrues on a balance if that
balance is paid in full by a specified
date or within a specified period of
time. In light of this confusion, the
Agencies believe that the January 2009
Rule focused too heavily on the form or
technical aspects of these programs.19
Deferred interest programs should not
be categorically prohibited while
waived interest programs are
categorically exempt from the
requirements of the final rule. Instead,
the Agencies believe the better approach
is to focus on applying consistent
standards to ensure that consumers are
not unfairly surprised by the cost of
using these types of promotional
programs. Accordingly, the Agencies
propose the following amendments.
As an initial matter, the Agencies
understand that the distinction in the
January 2009 Rule between ‘‘deferred
interest’’ programs and ‘‘waived
interest’’ programs could be read to
suggest that some programs were
covered by the final rule and others
were not. Because the protections
19 In particular, the Agencies understand that the
references in the January 2009 Rule to ‘‘assessing’’
or ‘‘charging’’ interest have caused uncertainty
about whether, during the promotional period, an
institution must treat accrued interest for which the
consumer may or may not ultimately be responsible
(depending on whether the balance is paid in full
prior to expiration) as part of the consumer’s debt.
The Agencies did not intend to regulate the
accounting treatment of this accrued interest.
Instead, the Agencies intended to ensure that
consumers understand the amount of interest for
which they will be responsible if the balance is not
paid in full before expiration. As discussed
elsewhere in this SUPPLEMENTARY INFORMATION, the
Board is proposing amendments to Regulation Z in
today’s Federal Register to accomplish this
purpose.
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consumers receive should not depend
on this technical distinction, the
Agencies propose to amend the
commentary to § l.24 to clarify that,
although institutions may continue to
provide promotional programs under
which the consumer will not be
obligated to pay interest that accrues on
a balance if that balance is paid in full
within a specified period of time, those
programs are subject to all of the
protections in § l.24, including the
general prohibition on so-called ‘‘hair
trigger’’ or ‘‘universal default’’
repricings of existing balances. See
proposed comments 24(a)–2.iv and
24(b)(3)–4.iii. Thus, for example, if a
consumer relies on this type of
promotional program when making a
purchase, the institution cannot deny
the consumer the opportunity to avoid
interest charges on that purchase by
paying the purchase in full prior to
expiration of the promotional period
unless the consumer is more than 30
days’ delinquent on the account.20
Furthermore, as discussed above, the
Agencies propose to amend the payment
allocation rules in § l.23 to ensure that
consumers are not required to pay off all
balances on the account in order to
receive the benefits of these types of
promotional programs. In addition,
elsewhere in today’s Federal Register,
the Board has proposed to amend the
advertising requirements in Regulation
Z, 12 CFR 226.16, to address concerns
that the use of terms such as ‘‘no
interest’’ to describe deferred or waived
interest programs may confuse
consumers. Specifically, whenever ‘‘no
interest’’ or a similar term is used in an
advertisement for a deferred or waived
interest program, proposed 12 CFR
226.16(h) would require the creditor to
disclose that any balance subject to the
program must be paid in full by the end
of the promotional period to avoid
interest charges (for example, ‘‘no
interest if paid in full within six
months’’). In addition, the creditor
would be required to state that, if the
balance subject to the program is not
paid in full within the promotional
period, interest will be charged from the
date the consumer became obligated for
each transaction subject to the
program.21 The Agencies believe that
20 If, however, the waived or deferred interest
balance is not paid in full on or before the date the
program expires, the institution is not required to
wait an additional 30 days before charging accrued
interest. See proposed comment 24(a)–2.iv.
21 As discussed above, the Board has also
proposed to amend the periodic statement
disclosures in Regulation Z, 12 CFR 226.7, to ensure
that consumers who utilize these types of
promotional programs are informed of the date on
which the program expires and the amount of
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these amendments will ensure that
institutions can continue to offer
programs that provide substantial
benefits to consumers while protecting
consumers from unexpected increases
in the cost of completed transactions.
Finally, the Agencies understand that
there is some confusion regarding
implementation of the final rule with
respect to existing deferred interest
programs. As noted above, the effective
date of the January 2009 Rule is July 1,
2010. In the SUPPLEMENTARY
INFORMATION to that rule, the Agencies
provided guidance regarding the
implementation of § l.24. See 74 FR
5534. The Agencies did not, however,
address the effect of the rule on deferred
interest programs established prior to
the effective date that expire after that
date. The Agencies did not intend to
convert these programs into interest-free
loans by prohibiting an institution from
charging interest if the deferred interest
balance is not paid in full prior to
expiration of the deferred interest
period. However, the Agencies will not
permit institutions to continue practices
prohibited by the January 2009 Rule
after the effective date. Accordingly, if
a deferred interest program established
prior to the effective date permits a
consumer to avoid deferred interest
charges by paying the deferred interest
balance in full by a date that falls on or
after July 1, 2010, the institution may
charge deferred interest to the account
consistent with the terms of the
program, provided that: (1) Any
periodic statement mailed or delivered
on or after July 1, 2010 complies with
the disclosure requirements in 12 CFR
226.7 (as amended); and (2) as of July 1,
2010, the institution fully complies with
the protections in the January 2009 Rule
(as amended), including the payment
allocation requirements in proposed
§ l.23(b) and the prohibitions on ‘‘hair
trigger’’ and ‘‘universal default’’
repricings in § l.24.
24(c) Treatment of Protected Balances
The Agencies propose to amend
comment 24(c)(2)–1 to clarify that
§ l.24(c)(2) does not prohibit an
institution from continuing to assess a
periodic fee that was assessed before the
account had a protected balance or from
assessing fees such as late payment fees
if the only balance on the account is a
protected balance.
Requests for Comment
The Agencies request comment on:
• Whether institutions establish
separate categories of transactions based
interest for which they will be responsible if the
promotional balance is not paid in full by that date.
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on factors other than annual percentage
rates and, if so, for what reasons and
whether proposed comment 24–3
should be revised accordingly.
• Whether the proposed
implementation guidance regarding
deferred interest plans provides
sufficient protections for consumers and
flexibility for institutions.
Section l.25—Unfair Balance
Computation Method
Section l.25(a) prohibits institutions
from imposing finance charges on
balances on a consumer credit card
account based on balances for days in
billing cycles that precede the most
recent billing cycle as a result of the loss
of any time period provided by the
institution within which the consumer
may repay any portion of the credit
extended without incurring finance
charges. The prohibited practice is
sometimes referred to as ‘‘two-cycle’’ or
‘‘double-cycle’’ billing.
As discussed above, the Agencies are
proposing amendments to § l.23,
§ l.24, and Regulation Z that would
clarify the substantive and disclosure
requirements for promotional programs
under which a consumer will not be
obligated to pay interest that accrues on
a balance if that balance is paid in full
prior to a specified date or the
expiration of a specified period of time.
Consistent with these proposed
amendments, the Agencies also propose
to add a new comment 25(a)–3,
clarifying that § l.25 does not prohibit
the institution from charging accrued
interest under this type of program if the
balance is not paid in full prior to the
specified date.
IV. Regulatory Analysis
Section VIII of the SUPPLEMENTARY
INFORMATION to the January 2009 Rule
sets forth the Agencies’ respective
analyses under the Regulatory
Flexibility Act (5 U.S.C. 601 et seq.) and
the Paperwork Reduction Act of 1995
(44 U.S.C. 3506; 5 CFR part 1320
Appendix A.1). See 74 FR 5548–5551.
This section also sets forth the OTS’s
determinations with respect to
Executive Orders 12866 and 13132 and
the Unfunded Mandates Reform Act of
1995 as well as the NCUA’s
determinations with respect to
Executive Order 13132 and the Treasury
and General Government
Appropriations Act, 1999. See 74 FR
5551–5558. Because the proposed
amendments are clarifications and
would not, if adopted, alter the
substance of the analyses and
determinations accompanying the
January 2009 Rule, the Agencies
continue to rely on those analyses and
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20813
determinations for purposes of this
rulemaking.
V. Solicitation of Comments on Use of
Plain Language
Section 722 of the Gramm-LeachBliley Act requires the Board and OTS
to use plain language in all proposed
and final rules published after January
1, 2000. Additionally, NCUA’s goal is to
promulgate clear and understandable
regulations that impose minimal
regulatory burdens. Therefore, the
Agencies specifically invite your
comments on how to make this proposal
easier to understand.
List of Subjects
12 CFR Part 227
Banks, Banking, Credit,
Intergovernmental relations, Trade
practices.
12 CFR Part 535
Consumer credit, Consumer
protection, Credit, Credit cards,
Deception, Intergovernmental relations,
Savings associations, Trade practices,
Unfairness.
12 CFR Part 706
Credit, Credit unions, Deception,
Intergovernmental relations, Trade
practices, Unfairness.
Board of Governors of the Federal
Reserve System
12 CFR Chapter II
Text of Proposed Revisions
Certain conventions have been used
to highlight the proposed revisions.
New language is shown inside flboldtype arrowsfi while language that
would be deleted is set off with øboldtype brackets¿.
Authority and Issuance
For the reasons discussed in the joint
preamble, the Board proposes to further
amend 12 CFR part 227, as amended at
74 FR 5559, January 29, 2009, as set
forth below:
PART 227—UNFAIR OR DECEPTIVE
ACTS OR PRACTICES (REGULATION
AA)
1. Section 227.23 is revised to read as
follows:
§ 227.23 Unfair acts or practices regarding
allocation of payments.
When different annual percentage
rates apply to different balances on a
consumer credit card accountfl:
(a) General rule. Except as provided in
paragraph (b) of this sectionfi, the bank
must allocate any amount paid by the
consumer in excess of the required
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minimum periodic payment among the
balances using one of the following
methods:
fl(1)fi ø(a)¿ High-to-low method.
The amount paid by the consumer in
excess of the required minimum
periodic payment is allocated first to the
balance with the highest annual
percentage rate and any remaining
portion to the other balances in
descending order based on the
applicable annual percentage rate.
fl(2)fi ø(b)¿ Pro rata method. The
amount paid by the consumer in excess
of the required minimum periodic
payment is allocated among the
balances in the same proportion as each
balance bears to the total balance.
fl(b) Special rule for accounts subject
to certain promotional programs. When
a promotional program provides that a
consumer will not be obligated to pay
interest that accrues on a balance if that
balance is paid in full prior to the
expiration of a specified period of time,
the bank must allocate amounts paid by
the consumer in excess of the required
minimum periodic payment first to that
balance during the two billing cycles
immediately preceding expiration of the
specified period and any remaining
portion to the other balances consistent
with paragraph (a) of this section.fi
2. Section 227.24 is amended by
revising paragraph (b) to read as follows:
§ 227.24 Unfair acts or practices regarding
increases in annual percentage rates.
*
*
*
*
*
(b) Exceptions. The prohibition in
paragraph (a) of this section on
increasing annual percentage rates does
not apply where an annual percentage
rate may be increased pursuant to one
of the exceptions in this paragraph.
(1) Account opening disclosure
exception. An annual percentage rate for
a category of transactions may be
increased to flan annual percentage
ratefi øa rate¿ disclosed at account
opening upon expiration of a period of
time disclosed at account opening.
flThis exception does not permit
application of an increased annual
percentage rate disclosed at account
opening that is contingent on a
particular event or occurrence or that
may be applied at the bank’s
discretion.fi
(2) Variable rate exception. An annual
percentage rate for a category of
transactions that varies according to an
index that is not under the bank’s
control and is available to the general
public may be increased due to an
increase in the index.
(3) Advance notice exception. An
annual percentage rate for a category of
transactions may be increased pursuant
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to a notice under 12 CFR 226.9fl(b), (c),
or (g)fi ø(c) or (g)¿fl, provided that:
(i) If the bank discloses the increased
rate pursuant to 12 CFR 226.9(b), that
rate must not be applied to transactions
that occurred prior to provision of the
notice;
(ii) If the bank discloses the increased
rate pursuant to 12 CFR 226.9(c) or (g),
that rate must not be applied to
transactions that occurred within seven
days after provision of the notice; and
(iii) This exception does not permit an
increase in any annual percentage rate
during the first year after the account is
opened.fi øfor transactions that occur
more than seven days after provision of
the notice. This exception does not
permit an increase in any annual
percentage rate during the first year after
the account is opened.¿
(4) Delinquency exception. An annual
percentage rate may be increased due to
the bank not receiving the consumer’s
required minimum periodic payment
within 30 days after the due date for
that payment.
(5) Workout fland temporary
hardshipfi arrangement exception. An
annual percentage rate may be increased
due to the consumer’s flcompletion
offi øfailure to comply with the terms
of¿ a workout flor temporary
hardshipfi arrangement between the
bank and the consumer flor the
consumer’s failure to comply with the
terms of such an arrangementfi,
provided that the annual percentage rate
applicable to a category of transactions
following any such increase does not
exceed the rate that applied to that
category of transactions prior to
commencement of the øworkout¿
arrangement.
fl(6) Servicemembers Civil Relief Act
exception. An annual percentage rate
that has been decreased pursuant to 50
U.S.C. app. 527 may be increased once
that provision no longer applies,
provided that the annual percentage rate
applicable to a category of transactions
following any such increase does not
exceed the rate that applied to that
category of transactions prior to the
decrease.fi
*
*
*
*
*
3. In Supplement I to Part 227:
A. Add Section 227.21—Definitions.
B. Under Section 227.22—Unfair Acts
or Practices Regarding Time to Make
Payment, under 22(b) Compliance with
General Rule, paragraph 3. is revised.
C. Under Section 227.23—Unfair Acts
or Practices Regarding Allocation of
Payments:
(i) Paragraph 2., the heading of
paragraph 3., and paragraphs 4. and 6.
are revised;
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(ii) Redesignate 23(a) High-to-Low
Method as 23(a)(1) High-to-Low Method;
(iii) Under 23(a)(1) High-to-Low
Method, paragraph 1.v is added;
(iv) Redesignate 23(b) Pro Rata
Method as 23(a)(2) Pro Rata Method;
(v) Under 23(a)(2) Pro Rata Method,
paragraph 1. is revised; and
(vi) Add 23(b) Special Rule for
Accounts Subject to Certain
Promotional Programs.
D. Under Section 227.24—Unfair Acts
or Practices Regarding Increases in
Annual Percentage Rates:
(i) Paragraph 1. is revised;
(ii) Add paragraphs 2., 3., 4.;
(iii) Under 24(a) General Rule,
paragraphs 1., 2.i. introductory text,
2.iii. introductory text, and 2.iii.C. are
revised, and paragraph 2.iv is added;
(iv) Under 24(b) Exceptions, add
paragraph 1.;
(v) Under 24(b)(1) Account Opening
Disclosure Exception, paragraph 1.
introductory text is revised, paragraph
1.iii. and paragraph 2. are removed,
paragraph 3. is redesignated as
paragraph 2., the introductory text of
newly designated paragraph 2. is
revised, and paragraph 2.ii. is added;
(vi) Under 24(b)(2) Variable Rate
Exception, the heading of paragraph 5.
is revised;
(vii) Under 24(b)(3) Advance Notice
Exception, paragraphs 2. and 3. are
revised and paragraph 4. is added;
(viii) Revise 24(b)(5) Workout
Arrangement Exception;
(ix) Under 24(c) Treatment of
Protected Balances, under 24(c)(1)
Repayment, under Paragraph 24(c)(1)(i),
the heading of paragraph 2. is revised;
and
(x) Under 24(c) Treatment of
Protected Balances, under 24(c)(2) Fees
and Charges, paragraph 1. is revised.
E. Under Section 227.25—Unfair
Balance Computation Method, under
25(a) General Rule, paragraph 3. is
added.
*
*
*
*
*
Subpart C—Consumer Credit Card
Account Practices Rule
fl§ 227.21—Definitions
21(a)
Annual Percentage Rate
1. Use of ‘‘rate.’’ For purposes of
Subpart C, ‘‘rate’’ has the same meaning
as ‘‘annual percentage rate’’ unless
otherwise specified.
21(c)
Consumer Credit Card Account
1. Closed accounts. If a consumer
credit card account with an outstanding
balance is closed, the account continues
to be the same consumer credit card
account for purposes of Subpart C with
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respect to that balance. For example, if
a bank or a consumer closes a consumer
credit card account with an outstanding
balance, the bank would still be
prohibited from increasing the annual
percentage rate that applies to that
balance unless permitted by one of the
exceptions in § 227.24(b).
2. Acquired accounts. If, through
merger or acquisition (for example), a
bank acquires a consumer credit card
account with an outstanding balance,
the account continues to be the same
consumer credit card account for
purposes of Subpart C with respect to
that balance. For example, if a consumer
credit card account has a $1,000
purchase balance with an annual
percentage rate of 15% and the bank
that acquires that account applies an
18% rate to purchases, the bank would
be prohibited from applying the 18%
rate to the $1,000 balance unless
permitted by one of the exceptions in
§ 227.24(b).
3. Balance transfers.
i. Between accounts issued by the
same bank. If a balance is transferred
from a consumer credit card account
issued by a bank to another credit
account issued by the same bank or its
affiliate or subsidiary, the account
continues to be the same consumer
credit card account for purposes of
Subpart C with respect to that balance
unless the account to which the balance
is transferred is an open-end credit plan
secured by the consumer’s dwelling. For
example, if a consumer credit card
account has a $2,000 purchase balance
with an annual percentage rate of 15%
and that balance is transferred to
another consumer credit card account
issued by the same bank that applies an
18% rate to purchases, the bank would
be prohibited from applying the 18%
rate to the $2,000 balance unless
permitted by one of the exceptions in
§ 227.24(b). Additional circumstances in
which a balance is considered
transferred for purposes of this
comment include when:
A. A retail credit card with an
outstanding balance is replaced or
substituted with a cobranded general
purpose card that can be used with a
broader merchant base;
B. A credit card account with an
outstanding balance is replaced or
substituted with another credit card
account offering different features;
C. A credit card account with an
outstanding balance is consolidated or
combined with one or more other credit
card accounts into a single credit card
account; and
D. A credit card account is replaced
or substituted with a line of credit that
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can be accessed solely by an account
number.
ii. Between accounts issued by
different institutions. If a balance is
transferred to a consumer credit card
account issued by a bank from a credit
account issued by a different bank or an
institution that is not an affiliate or
subsidiary of the bank that issued the
consumer credit card account, the
account is not the same consumer credit
card account for purposes of Subpart C
with respect to that balance. Thus, the
provisions of Subpart C do not prohibit
the bank to which the balance is
transferred from applying its account
terms to that balance, provided that
those terms comply with Subpart C. For
example, if a consumer credit card
account issued by bank A has a $1,000
purchase balance at an annual
percentage rate of 15% and the
consumer transfers that balance to a
consumer credit card account with a
purchase rate of 17% issued by bank B,
bank B may apply the 17% rate to the
$1,000 balance. However, bank B may
not subsequently increase the rate on
that balance unless permitted by one of
the exceptions in § 227.24(b).fi
§ 227.22—Unfair Acts or Practices
Regarding Time To Make Payment
*
*
22(b)
*
*
*
Compliance With General Rule
*
*
*
*
*
3. Example of alternative method of
compliance. Assume that, for a
particular type of consumer credit card
account, a bank only provides periodic
statements electronically and only
accepts payments electronically
(consistent with applicable law and
regulatory guidancefl, including the
consumer notice and consent
procedures of the Electronic Signatures
in Global and National Commerce Act
(E-Sign Act), 15 U.S.C. 7001 et seq.fi).
Under these circumstances, the bank
could comply with § 227.22(a) even if it
does not provide periodic statements 21
days before the payment due date
consistent with § 227.22(b)(2).
§ 227.23—Unfair Acts or Practices
Regarding Allocation of Payments
*
*
*
*
*
2. Adjustments of one dollar or less
permitted. When allocating payments,
the bank may adjust amounts by one
dollar or less. For example, if a bank is
allocating $100 pursuant to
§ 227.23fl(a)(2)fiø(b)¿ among balances
of $1,000, $2,000, and $4,000, the bank
may apply $14 to the $1,000 balance,
$29 to the $2,000 balance, and $57 to
the $4,000 balance.
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20815
3. Applicable balances and øannual
percentage¿ rates. * * *
4. Use of permissible allocation
methods. A bank is not prohibited from
changing the allocation method for a
consumer credit card account or from
using different allocation methods for
different consumer credit card accounts,
so long as the methods used are
consistent with § 227.23. For example, a
bank may change from allocating to the
highest rate balance first pursuant to
§ 227.23(a)fl(1)fi to allocating pro rata
pursuant to § 227.23fl(a)(2)fiø(b)¿ or
vice versa. Similarly, a bank may
allocate to the highest rate balance first
pursuant to § 227.23(a)fl(1)fi on some
of its accounts and allocate pro rata
pursuant to § 227.23fl(a)(2)fiø(b)¿ on
other accounts.
*
*
*
*
*
6. Balances with the same øannual
percentage¿ rate. When the same annual
percentage rate applies to more than one
balance on an account and a different
annual percentage rate applies to at least
one other balance on that account,
§ 227.23 flgenerallyfi does not require
that any particular method be used
when allocating among the balances
with the same annual percentage rate.
Under these circumstances, a bank may
treat the balances with the same rate as
a single balance or separate balances.
See comments 23(a)fl(1)fi–1.iv and
23fl(a)(2)fiø(b)¿–2.iv. flHowever,
when a consumer will not be obligated
to pay interest that accrues on a balance
if that balance is paid in full prior to the
expiration of a specified period of time,
that balance must be treated as a balance
with an annual percentage rate of zero
for purposes of § 227.23 during that
period of time. For example, if an
account has a $1,000 purchase balance
and a $2,000 balance on which the
consumer will not be obligated to pay
interest if that balance is paid in full
prior to July 1 and a 15% annual
percentage rate applies to both, the
balances must be treated as balances
with different rates for purposes of
§ 227.23 until July 1. In addition, for
purposes of allocating pursuant to
§ 227.23(a)(1), any amount paid by the
consumer in excess of the required
minimum periodic payment must be
applied first to the $1,000 purchase
balance except during the last two
billing cycles of the promotional period
(when it must be applied first to any
remaining portion of the $2,000
balance). See comment 23(a)(1)–1.v.fi
23(a)fl(1)fi High-to-Low Method
1. * * *
flv. Assume that on January 1 a
consumer uses a credit card account to
make a $1,200 purchase subject to a
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promotional offer under which interest
accrues at an annual percentage rate of
15% but the consumer will not be
obligated to pay that interest if the
balance is paid in full on or before June
30. The billing cycles for this account
begin on the first day of the month and
end on the last day of the month. Each
month from January through June, the
consumer uses the account to make
$200 in purchases that are not subject to
the promotional offer but are subject to
the 15% rate. Each month from
February through June, the consumer
pays $400 in excess of the required
minimum periodic payment on the
payment due date, which is the twentyfifth of the month. Any interest that
accrues on the non-promotional
purchases is paid by the required
minimum periodic payment. A bank
using this method would allocate the
$400 excess payments received on
February 25, March 25, and April 25 as
follows: $200 to pay off the nonpromotional balance (that is subject to
the 15% rate) and the remaining $200 to
the promotional balance (that is treated
as a balance with a rate of zero). Section
227.23(b), however, requires the bank to
allocate the entire $400 excess payment
received on May 25 to the promotional
balance. Similarly, § 227.23(b) requires
the bank to allocate the $400 excess
payment received on June 25 as follows:
$200 to the promotional balance (which
pays that purchase in full) and the
remaining $200 to the non-promotional
balance.fi
23fl(a)(2)fiø(b)¿
Pro Rata Method
1. Total balance. A bank may, but is
not required to, deduct amounts paid by
the consumer’s required minimum
periodic payment when calculating the
total balance for purposes of
§ 227.23fl(a)(2)fiø(b)(3)¿. See
comment 23fl(a)(2)fiø(b)¿–2.iii.
*
*
*
*
*
fl23(b) Special Rule for Accounts
Subject to Certain Promotional
Programs
1. Grace periods. Section 227.23(b)
applies to promotional programs under
which the consumer is not obligated to
pay interest that accrues on a balance if
that balance is paid in full prior to the
expiration of a specified period of time.
A grace period during which a
consumer may repay one or more
balances on a consumer credit card
account is not a ‘‘promotional program’’
for purposes of § 227.23(b).fi
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§ 227.24—Unfair Acts or Practices
Regarding Increases in Annual
Percentage Rates
1. Relationship to Regulation Z, 12
CFR part 226. A bank that complies
with the applicable disclosure
requirements in Regulation Z, 12 CFR
part 226, has complied with the
disclosure requirements in § 227.24. See
12 CFR 226.5a, 226.6, 226.9. For
example, a bank may comply with the
requirement in § 227.24(a) to disclose at
account opening the annual percentage
rates that will apply to each category of
transactions by complying with the
disclosure requirements in 12 CFR
226.5a regarding applications and
solicitations and the requirements in 12
CFR 226.6 regarding account-opening
disclosures. Similarly, in order to
increase an annual percentage rate on
new transactions pursuant to
§ 227.24(b)(3), a bank must comply with
the disclosure requirements in 12 CFR
226.9fl(b), (c), or (g)fi ø(c) or (g)¿.
However, nothing in § 227.24 alters the
requirements in 12 CFR 226.9(c) and (g)
that creditors provide consumers with
written notice at least 45 days prior to
the effective date of certain increases in
the annual percentage rates on open-end
(not home-secured) credit plans.
fl2. Relationship to grace period.
Nothing in § 227.24 prohibits a bank
from assessing interest due to the loss of
a grace period to the extent consistent
with § 227.25. In addition, a bank has
not reduced an annual percentage rate
on a consumer credit account for
purposes of § 227.24 if the bank does
not charge interest on a balance when
the consumer pays that balance in full
prior to the expiration of a grace period.
3. Category of transactions. For
purposes of § 227.24, a ‘‘category of
transactions’’ is a type or group of
transactions to which an annual
percentage rate applies that is different
than the annual percentage rate that
applies to other transactions. For
example, purchase transactions, cash
advance transactions, and balance
transfer transactions are separate
categories of transactions for purposes
of § 227.24 if a bank applies different
annual percentage rates to each.
Furthermore, if, for example, the bank
applies different annual percentage rates
to different types of purchase
transactions (such as one rate for
purchases of gasoline and a different
rate for all other purchases), each type
constitutes a separate category of
transactions for purposes of § 227.24.
4. Account opening.
i. Multiple accounts with same bank.
When a consumer has a credit card
account with a bank and the consumer
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opens a new credit card account with
the same bank (or its affiliate or
subsidiary), the opening of the new
account constitutes an ‘‘account
opening’’ for purposes of § 227.24 if,
more than 15/30 days after the new
account is opened, the consumer has the
ability to obtain additional extensions of
credit on each account. For example,
assume that, on January 1 of year one,
a consumer opens a credit card account
with a bank. On July 1 of year one, the
consumer opens a second credit card
account with that bank. On July 15, a
$1,000 balance is transferred from the
first account to the second account. The
opening of the second account
constitutes the opening of an account
for purposes of § 227.24 so long as, on
July 17/August 1, the consumer can
engage in transactions using either
account. Under these circumstances, the
bank could not increase an annual
percentage rate on the second account
pursuant to § 227.24(b)(3) until July 1 of
year two (which is one year after the
second account was opened).
ii. Replacement or consolidation.
A. Generally. A consumer credit card
account has not been opened for
purposes of § 227.24 when a consumer
credit card account issued by a bank is
replaced or consolidated with another
consumer credit card account issued by
the same bank (or its affiliate or
subsidiary). Circumstances in which a
consumer credit card account has not
been opened for purposes of § 227.24
include when:
(1) A retail credit card is replaced
with a cobranded general purpose card
that can be used at a wider number of
merchants;
(2) A credit card account is replaced
with another consumer credit card
account offering different features;
(3) A credit card account is
consolidated or combined with one or
more other credit card accounts into a
single credit card account; or
(4) A credit card account acquired
through merger or acquisition is
replaced with a credit card account
issued by the acquiring bank.
B. Limitation. A bank that replaces or
consolidates a consumer credit card
account with another consumer credit
card account issued by the bank (or its
affiliate or subsidiary) may not increase
an annual percentage rate in a manner
otherwise prohibited by § 227.24. For
example, assume that, on January 1 of
year one, a consumer opens a consumer
credit card account with an annual
percentage rate for purchases of 15%.
On July 1 of year one, the account is
replaced with a consumer credit card
account that offers different features
(such as rewards on purchases). Under
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these circumstances, the bank cannot
increase the annual percentage rate for
purchases to a rate that is higher than
15% pursuant to § 227.24(b)(3) until
January 1 of year two (which is one year
after the first account was opened).fi
24(a) General Rule
1. Rates that will apply to each
category of transactions. Section
227.24(a) requires banks to disclose, at
account opening, the annual percentage
rates that will apply to each category of
transactions on the account. A bank
cannot satisfy this requirement by
disclosing at account opening only a
range of rates or that a rate will be ‘‘up
to’’ a particular amount. flThe
disclosure requirements in § 227.24(a)
do not apply to annual percentage rates
that are contingent on a particular event
or occurrence or may be applied at the
bank’s discretion (such as penalty rates)
insofar as those rates may be applied
consistent with § 227.24.fi
2. * * *
i. Assume that, at account opening on
January 1 of year one, a bank discloses
that the annual percentage rate for
purchases is a non-variable rate of 15%
and will apply for six months. The bank
also discloses that, after six months, the
annual percentage rate for purchases
will be a variable rate that is currently
18% and will be adjusted quarterly by
adding a margin of 8 percentage points
to a publicly available index not under
the bank’s control. flFurthermore,fi
øFinally,¿ the bank discloses that the
annual percentage rate for cash
advances is the same variable rate that
will apply to purchases after six
months. flFinally, the bank discloses
that, to the extent consistent with
§ 227.24 and other applicable law, a
non-variable penalty rate of 30% may
apply if the consumer makes a late
payment.fi The payment due date for
the account is the twenty-fifth day of the
month and the required minimum
periodic payments are applied to
accrued interest and fees but do not
reduce the purchase and cash advance
balances.
*
*
*
*
*
iii. Assume that, at account opening
on January 1 of year one, a bank
discloses that the annual percentage rate
for purchases is a variable rate
determined by adding a margin of 6
percentage points to a publicly-available
index outside of the bank’s control. The
bank also discloses that, to the extent
consistent with § 227.24 and other
applicable law, a non-variable penalty
rate of 28% may apply if the consumer
makes a late payment. The due date for
the account is the fifteenth of the
month. On May 30 of year two, the
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22:39 May 04, 2009
Jkt 217001
account has a purchase balance of
$1,000. On May 31, the creditor
provides a notice pursuant to 12 CFR
226.9(c) informing the consumer of a
new variable rate that will apply on July
16 for all purchases made on or after
June 8 (calculated by using the same
index and an increased margin of 8
percentage points). On June 7, the
consumer makes a $500 purchase. On
June 8, the consumer makes a $200
purchase. On June 25, the bank has not
received the payment due on June 15
and provides the consumer with a
notice pursuant to 12 CFR 226.9(g)
stating that the penalty rate of 28% will
apply as of August 9 to all transactions
made on or after July 3 fland that, if the
consumer becomes more than 30 days
late, the penalty rate will apply to all
balances on the accountfi. On July 4,
the consumer makes a $300 purchase.
*
*
*
*
*
C. Same facts as paragraph A. above
except the payment due on June 15 of
year two is received on July 20. Section
227.24(b)(4) permits the bank to apply
the 28% penalty rate to all balances on
the account and to future transactions
because it has not received payment
within 30 days after the due date.
Because the bank provided a 12 CFR
226.9(g) notice on June fl25fiø24¿
stating the 28% penalty rate, the bank
may apply the 28% penalty rate to all
balances on the account as well as any
future transactions on August 9 without
providing an additional notice pursuant
to 12 CFR 226.9(g).
fliv. Assume that, at account opening
on January 1 of year one, the bank
discloses a promotional program under
which interest on purchases made
during January will accrue at a nonvariable rate of 20%, but the consumer
will not be obligated to pay that interest
if those purchases are paid in full by
December 31 of year one. On January 15,
the consumer makes a purchase of
$2,000. No other transactions are made
on the account. The payment due on
April 1 is not received until April 10.
Section 227.24 does not permit the bank
to deny the consumer the opportunity to
avoid interest charges on the $2,000
purchase by paying that purchase in full
on or before December 31 of year one.
If, however, the $2,000 purchase
remains unpaid on January 1 of year
two, § 227.24 does not prohibit the bank
from charging the interest accrued on
that purchase during year one.fi
24(b) Exceptions
fl1. Delayed implementation of rate
increase. If § 227.24(b) permits a bank to
apply an increased annual percentage
rate on a date that is not the first day
of a billing cycle, the bank may delay
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20817
application of the increased rate until
the first day of the following billing
cycle without relinquishing the ability
to apply that rate. For example, assume
that, at account opening on January 1,
a bank discloses that a non-variable
annual percentage rate of 10% will
apply to purchases for six months and
a non-variable rate of 15% will apply
thereafter. The first day of the billing
cycle for the account is the fifteenth of
the month. If the six-month period
expires on July 1, the bank may delay
application of the 15% rate until July 15
without relinquishing its ability to
apply that rate under § 227.24(b)(1).fi
24(b)(1) Account Opening Disclosure
Exception
1. Prohibited increases in rate.
Section § 227.24(b)(1) permits an
increase in the annual percentage rate
for a category of transactions to a rate
disclosed at account opening upon
expiration of a period of time that was
also disclosed at account opening.
Section 227.24(b)(1) does not permit
application of flan increased annual
percentage ratefi øincreased rates that
are¿ disclosed at account opening
flthat isfi øbut are¿ contingent on a
particular event or occurrence or
flthatfi may be applied at the bank’s
discretion. The following examples
illustrate rate increases that are not
permitted by § 227.24ø(a)¿:
*
*
*
*
*
øiii. Assume that a bank discloses at
account opening on January 1 of year
one that interest on purchases will be
deferred for one year, although interest
will accrue on purchases during that
year at a non-variable rate of 20%. The
bank further discloses that, if all
purchases made during year one are not
paid in full by the end of that year, the
bank will begin charging interest on the
purchase balance and new purchases at
20% and will retroactively charge
interest on the purchase balance at a
rate of 20% starting on the date of each
purchase made during year one. On
January 1 of year one, the consumer
makes a purchase of $1,500. No other
transactions are made on the account.
On January 1 of year two, $500 of the
$1,500 purchase remains unpaid.
Section 227.24 does not permit the bank
to reach back to charge interest on the
$1,500 purchase from January 1 through
December 31 of year one. However, the
bank may apply the previouslydisclosed 20% rate to the $500 purchase
balance beginning on January 1 of year
two (pursuant to § 227.24(b)(1)).¿
ø2. Loss of grace period. Nothing in
§ 227.24 prohibits a bank from assessing
interest due to the loss of a grace period
to the extent consistent with § 227.25.¿
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fl2.fi ø3.¿ Application of rate that is
lower than disclosed rate. Section
§ 227.24(b)(1) permits an increase in the
annual percentage rate for a category of
transactions to a rate disclosed at
account opening upon expiration of a
period of time that was also disclosed at
account opening. Nothing in § 227.24
prohibits a bank from applying a rate
that is lower than flafi øthe¿ disclosed
rate fleither during orfi upon
expiration of the period. However,
flonce thefi øif a¿ lower rate is applied
to an existing balance, the bank cannot
subsequently increase the rate on that
balance unless it øhas¿ provided the
consumer with advance notice of the
increase pursuant to 12 CFR
226.9fl(b)fi or (c). flThis notice must
state the period of time during which
the lower rate will apply and the rate
that will apply after expiration of that
period.fi Furthermore, fla bank that
applies a lower rate to transactions that
occurred during the first year after
account opening may not subsequently
increase the rate that applies to those
transactions to a rate that is higher than
the increased rate disclosed at account
openingfi øthe bank cannot increase
the rate on that existing balance to a rate
that is higher than the increased rate
disclosed at account opening¿. The
following flexamples illustratefi
øexample illustrates¿ the application of
flthefi øthis¿ rule:
*
*
*
*
*
flii. Assume that a bank discloses at
account opening on January 1 of year
one that a non-variable annual
percentage rate of 15% will apply to
purchases for one year, after which that
rate will increase to a non-variable rate
of 18%. The bank also discloses that, to
the extent consistent with § 227.24 and
other applicable law, a non-variable
penalty rate of 30% may apply if the
consumer’s required minimum periodic
payment is received after the payment
due date, which is the tenth of the
month. The required minimum periodic
payments are applied to accrued interest
and fees but do not reduce the purchase
balance.
A. On September 30 of year one, the
account has a purchase balance of
$1,400 at the 15% rate. On October 1,
the bank provides a notice pursuant to
12 CFR 226.9(c) informing the consumer
that the rate for new purchases will
decrease to a non-variable rate of 10%
for six months (from October 1 through
March 31 of year two) and that,
beginning on April 1 of year two, the
rate for purchases will increase to a nonvariable rate of 20%. The bank does not
apply the 10% rate to the $1,400
purchase balance. On October 15 of year
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Jkt 217001
one, the consumer makes a $300
purchase at the 10% rate. On January 1
of year two, the bank may begin
accruing interest on the $1,400 purchase
balance at 18% (as disclosed at account
opening). On January 15 of year two, the
consumer makes a $150 purchase at the
10% rate. On April 1 of year two, the
10% rate that applies to the $300
purchase and the $150 purchase
expires. The bank may begin accruing
interest on the $150 purchase at 20% (as
disclosed in the 12 CFR 226.9(c) notice).
Because, however, the $300 purchase
occurred during the first year after
account opening, the bank cannot
increase the rate that applies to that
purchase to a rate that is higher than the
18% rate disclosed at account opening.
B. Same facts as above except that the
required minimum periodic payment
due on November 10 of year one is not
received until November 15. Section
227.24(b)(1) does not permit the bank to
increase any annual percentage rate on
the account at this time. The bank may,
however, apply the 30% penalty rate to
new transactions beginning on January
1 of year two pursuant to § 227.24(b)(3)
by providing a 12 CFR 226.9(g) notice
informing the consumer of this increase
no later than November 16 of year one.
On January 1 of year two, § 227.24(b)(1)
permits the bank to begin accruing
interest on the $1,400 purchase balance
at 18% (as disclosed at account
opening). If the consumer makes the
$150 purchase on January 15 of year
two, § 227.24(b)(3) would permit the
bank to apply the 30% rate to that
purchase. On April 1 of year two, the
10% rate that applies to the $300
purchase expires. Because this purchase
occurred during the first year after
account opening, the bank cannot
increase the rate that applies to that
purchase to a rate that is higher than the
18% rate disclosed at account
opening.fi
24(b)(2)
Variable Rate Exception
*
*
*
*
*
5. Changing a variable øannual
percentage¿ rate to a non-variable
øannual percentage¿ rate. * * *
*
*
*
*
*
24(b)(3)
Advance Notice Exception
*
*
*
*
*
2. Transactions that floccurred prior
to provision of notice or within seven
days after provision of noticefi øoccur
more than seven days after notice
provided¿. flSection 227.24(b)(3)
generally permits a bank to apply an
increased rate to transactions that occur
after provision of a 12 CFR 226.9(b)
notice or more than seven days after
provision of a 12 CFR 226.9(c) or (g)
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notice. If a rate increase is disclosed
pursuant to both 12 CFR 226.9(b) and 12
CFR 226.9(c), that rate may only be
applied to transactions that occur more
than seven days after provision of the 12
CFR 226.9(c) notice. Section
227.24(b)(3) does not permit a bank to
reach back to days before the effective
date of the rate increase under 12 CFR
226.9(c) or (g) when calculating interest
charges. See comment 24(b)(3)–3.fi
øSection 227.24(b)(3) generally
prohibits a bank from applying an
increased rate to transactions that occur
within seven days after provision of the
12 CFR 226.9 (c) or (g) notice.¿
flWhether a transaction occurred prior
to provision of a notice or within seven
days after provision of a notice is
determined by the date of the
transaction. In some cases, however, a
merchant may place a ‘‘hold’’ on the
available credit on an account for an
estimated transaction amount when the
actual transaction amount will not be
known until a later date. In these
circumstances, the date of the
transaction for purposes of
§ 227.24(b)(3) is the date on which the
merchant determines the actual
transaction amount. For example,
assume that, when a consumer uses a
credit card account to check into a hotel
on July 1, the hotel obtains
authorization for a $750 hold on the
account to ensure there is adequate
available credit to cover the anticipated
cost of the stay. When the consumer
checks out on July 4, the actual cost of
the stay is $850 because of additional
incidental costs, and the hotel charges
this amount to the account. For
purposes of § 227.24(b)(3), the
transaction occurred on July 4.fi øThis
prohibition does not, however, apply to
transactions that are authorized within
seven days after provision of the 12 CFR
226.9 (c) or (g) notice but are settled
more than seven days after the notice
was provided.¿
3. Examples.
i. Assume that a consumer credit card
account is opened on January 1 of year
one. On March 14 of year two, the
account has a purchase balance of
$2,000 at a non-variable annual
percentage rate of 15%. On March 15,
the bank provides a notice pursuant to
12 CFR 226.9(c) informing the consumer
that the rate for new purchases will
increase to a non-variable rate of 18%
on May 1. The notice further states that
the 18% rate will apply for six months
(until November 1) and states that
thereafter the bank will apply a variable
rate that is currently 22% and is
determined by adding a margin of 12
percentage points to a publicly-available
index that is not under the bank’s
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control. The seventh day after provision
of the notice is March 22 and, on that
date, the consumer makes a $200
purchase. On March 24, the consumer
makes a $1,000 purchase. On May 1,
§ 227.24(b)(3) permits the bank to begin
accruing interest at 18% on the $1,000
purchase made on March 24. The bank
is not permitted to apply the 18% rate
to the $2,200 purchase balance as of
March 22. After six months (November
2), the bank may begin accruing interest
on any remaining portion of the $1,000
purchase at the previously-disclosed
variable rate determined using the 12point margin.
øii. Same facts as above except that
the $200 purchase is authorized by the
bank on March 22 but is not settled
until March 23. On May 1, § 227.24(b)(3)
permits the bank to start charging
interest at 18% on both the $200
purchase and the $1,000 purchase. The
bank is not permitted to apply the 18%
rate to the $2,000 purchase balance as
of March 22.¿
flii.fi øiii.¿ Same facts as øin
paragraph i.¿ above except that on
September 17 of year two (which is 45
days before expiration of the 18% nonvariable rate), the bank provides a notice
pursuant to 12 CFR 226.9(c) informing
the consumer that, on November 2, a
new variable rate will apply to new
purchases and any remaining portion of
the $1,000 balance (calculated by using
the same index and a reduced margin of
10 percentage points). The notice
further states that, on May 1 of year
three, the margin will increase to the
margin disclosed flin the March 15
noticefi øat account opening¿ (12
percentage points). On May 1 of year
three, § 227.24(b)(3) permits the bank to
increase the margin used to determine
the variable rate that applies to new
purchases to 12 percentage points and
to apply that rate to any remaining
portion of the $1,000 purchase as well
as to new purchases. øSee comment
24(b)(1)–3.¿ The bank is not permitted
to apply this rate to any remaining
portion of the $2,200 purchase balance
as of March 22.
fl4. Application of a lower rate.
Nothing in § 227.24 prohibits a bank
from lowering the annual percentage
rate that applies to an existing balance
or to new transactions. However, once
the lower rate is applied to an existing
balance, the bank cannot subsequently
increase the rate on that balance unless
it provided the consumer with advance
notice of the increase pursuant to 12
CFR 226.9(b) or (c). This notice must
state the period of time during which
the lower rate will apply and the rate
that will apply after expiration of that
period. Furthermore, a bank that applies
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22:39 May 04, 2009
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a decreased rate to transactions that
occurred prior to provision of the
notice—or, in the case of a 12 CFR
226.9(c) or (g) notice, transactions that
occurred within seven days after
provision of the notice—may not
subsequently increase the rate that
applies to those transactions to a rate
that is higher than the rate that applied
prior to the decrease. The following
examples illustrate the application of
the rule:
i. Assume that a bank discloses at
account opening on January 1 of year
one that a non-variable annual
percentage rate of 10% will apply to
purchases for one year, after which that
rate will increase to a non-variable rate
of 15%. The bank also discloses that, to
the extent consistent with § 227.24 and
other applicable law, a non-variable
penalty rate of 30% may apply if the
consumer’s required minimum periodic
payment is received after the payment
due date, which is the tenth of the
month. The required minimum periodic
payments are applied to accrued interest
and fees but do not reduce the purchase
balance. On June 30 of year two, the
account has a purchase balance of
$1,000 at the 15% rate. On July 1, the
bank provides a notice pursuant to 12
CFR 226.9(c) informing the consumer
that the rate for new purchases will
decrease to a non-variable rate of 5% for
six months (from July 1 through
December 31 of year two) and that,
beginning on January 1 of year three, the
rate for purchases will increase to a nonvariable rate of 17%. On July 8 of year
two, the consumer makes a $200
purchase. On July 9, the consumer
makes a $100 purchase. On January 1 of
year three, § 227.24(b)(3) permits the
bank to begin accruing interest on the
$100 purchase at 17%. The bank may
not apply the 17% rate to the $200
purchase because that transaction
occurred within seven days after
provision of the 12 CFR 226.9(c) notice.
If the bank applied the 5% rate to the
$1,000 purchase balance and the $200
purchase, the bank may not increase the
rate that applies to those amounts to a
rate that is higher than 15% on January
1 of year three.
ii. Same facts as above except that the
required minimum periodic payment
due on September 10 of year two is not
received until September 15 of year two.
On September 15 of year two, the bank
provides a notice pursuant to 12 CFR
226.9(g) informing the consumer that
the rate for new purchases will increase
to the 30% penalty rate on October 31.
On October 31, § 227.23(b)(3) permits
the bank to begin accruing interest at
30% on any purchase made on or after
September 23. The bank may not,
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20819
however, apply the 30% rate to the
$1,300 in purchases. Instead, the bank
must continue to apply the 5% rate to
the $100 purchase until at least January
1 of year three when § 227.24(b)(3)
permits the bank to begin accruing
interest on that purchase at 17%.
Similarly, if the bank applied the 5%
rate to the $1,000 purchase balance and
the $200 purchase, the bank may begin
accruing interest on those amounts at
15% on January 1 of year three.
iii. Assume that a bank discloses at
account opening on January 1 of year
one that the rate that applies to
purchases is a variable annual
percentage rate that is currently 18%
and will be adjusted quarterly by adding
a margin of 8 percentage points to a
publicly available index not under the
bank’s control. The bank also discloses
that, to the extent consistent with
§ 227.24 and other applicable law, a
non-variable penalty rate of 30% may
apply if the consumer’s required
minimum periodic payment is received
after the payment due date, which is the
first of the month. On July 30 of year
two, the consumer uses the account for
a $1,000 purchase in response to a
promotional offer. Under the terms of
this offer, interest on purchases made
during the months of July through
September will accrue at the variable
rate for purchases but the consumer will
not be obligated to pay that interest if
all purchases made during that threemonth period are paid in full by
December 31 of year two. The payment
due on September 1 of year two is not
received until September 6. Section
227.24 does not permit the bank to deny
the consumer the opportunity to avoid
interest charges on the $1,000 purchase
by paying that purchase in full on or
before December 31 of year two. The
bank may, however, provide a notice
pursuant to 12 CFR 226.9(g) on
September 2 of year two informing the
consumer that the promotional offer
does not apply to purchases made on or
after September 10 and that the rate for
such purchases will increase to the 30%
penalty rate on October 18. On
December 31 of year two, the $1,000
purchase has been paid in full. Under
these circumstances, the bank may not
charge any interest accrued on the
$1,000 purchase.
iv. Assume that a bank discloses at
account opening on January 1 of year
one that the rate that applies to cash
advances is a variable annual percentage
rate that is currently 24% and will be
adjusted quarterly by adding a margin of
14 percentage points to a publicly
available index not under the bank’s
control. On July 1 of year two, the bank
provides checks that access the account
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and, pursuant to 12 CFR 226.9(b)(3)(A),
discloses that a promotional rate of 15%
will apply to credit extended by use of
the checks until January 1 of year three,
after which the cash advance rate
determined using the 14-point margin
will apply. On July 15 of year two, the
consumer uses one of the checks to pay
for a $500 transaction. On January 1 of
year three, § 227.24(b)(3) permits the
bank to apply the cash advance rate
determined using the 14-point margin to
the $500 transaction.fi
24(b)(5) Workout fland Temporary
Hardshipfi Arrangement Exception
1. Scope of exception. Nothing in
§ 227.24(b)(5) permits a bank to alter the
requirements of § 227.24 pursuant to a
workout flor temporary hardshipfi
arrangement between a consumer and
the bank. For example, a bank cannot
increase an annual percentage rate
pursuant to a workout flor temporary
hardshipfi arrangement unless
otherwise permitted by § 227.24. In
addition, a bank cannot require the
consumer to make payments with
respect to a protected balance that
exceed the payments permitted under
§ 227.24(c).
2. Variable øannual percentage¿
rates. If the annual percentage rate that
applied to a category of transactions
prior to commencement of the workout
flor temporary hardshipfi arrangement
varied with an index consistent with
§ 227.24(b)(2), the rate applied to that
category of transactions following an
increase pursuant to § 227.24(b)(5) must
be determined using the same formula
(index and margin).
3. Exampleflsfi.
fli.fi Assume that, consistent with
§ 227.24(b)(4), the margin used to
determine a variable annual percentage
rate that applies to a $5,000 balance is
increased from 5 percentage points to 15
percentage points. Assume also that the
bank and the consumer subsequently
agree to a workout arrangement that
reduces the margin back to 5 points on
the condition that the consumer pay a
specified amount by the payment due
date each month. If the consumer does
not pay the agreed-upon amount by the
payment due date, the bank may
increase the margin for the variable rate
that applies to the $5,000 balance up to
15 percentage points. 12 CFR 226.9 does
not require advance notice of this type
of increase.
flii. Assume that a consumer fails to
make four consecutive minimum
payments totaling $480 on a consumer
credit card account with a balance of
$6,000 and that, consistent with
§ 227.24(b)(4), the annual percentage
rate that applies to that balance is
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Jkt 217001
increased from a non-variable rate of
15% to a non-variable penalty rate of
30%. Assume also that the bank and the
consumer subsequently agree to a
temporary hardship arrangement that
reduces all rates on the account to 0%
on the condition that the consumer pay
an amount by the payment due date
each month that is sufficient to cure the
$480 delinquency within six months. If
the consumer pays the agreed-upon
amount by the payment due date during
the six-month period and cures the
delinquency, the bank may increase the
rate that applies to any remaining
portion of the $6,000 balance to 15% or
any other rate up to the 30% penalty
rate.fi
24(c)
*
Treatment of Protected Balances
*
*
24(c)(1)
*
*
*
*
Repayment
*
*
*
Paragraph 24(c)(1)(i)
*
*
*
*
*
2. Amortization when applicable
øannual percentage¿ rate is variable.
* * *
*
*
*
*
*
24(c)(2) Fees and Charges
1. Fee or charge based solely on the
protected balance. A bank is prohibited
from assessing a fee or charge based
solely on balances to which § 227.24(c)
applies. For example, a bank is
prohibited from assessing a monthly
maintenance fee that would not be
charged if the account did not have a
protected balance. A bank is not,
however, prohibited from flcontinuing
to assess a periodic fee that was
assessed before the account had a
protected balance.fi flSimilarly, a
bank is not prohibited fromfi assessing
fees such as late payment fees or fees for
exceeding the credit limit even if such
fees are based in part on the protected
balance flor if the only balance on the
account is a protected balancefi.
§ 227.25—Unfair Balance Computation
Method
25(a)
General Rule
*
*
*
*
*
fl3. Charging accrued interest at
expiration of certain promotional
programs. When a bank offers a
promotional program under which a
consumer will not be obligated to pay
interest that accrues on a balance if that
balance is paid in full prior to a
specified date or expiration of a
specified period of time, § 227.25 does
not prohibit the bank from charging that
accrued interest to the account if the
balance is not paid in full prior to the
PO 00000
Frm 00018
Fmt 4701
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specified date (consistent with
applicable law and regulatory
guidance).fi
*
*
*
*
*
Department of the Treasury
Office of Thrift Supervision
12 CFR Chapter V
Text of Proposed Revisions
Certain conventions have been used
to highlight the proposed revisions.
New language is shown inside flboldtype arrowsfi while language that
would be deleted is set off with øboldtype brackets¿.
Authority and Issuance
For the reasons discussed in the joint
preamble, OTS proposes to further
amend 12 CFR part 535, as amended at
74 FR 5567, January 29, 2009, as set
forth below:
PART 535—UNFAIR OR DECEPTIVE
ACTS OR PRACTICES
1. Section 535.23 is revised to read as
follows:
§ 535.23
Unfair allocation of payments.
When different annual percentage
rates apply to different balances on a
consumer credit card accountfl:
(a) General rule. Except as provided in
paragraph (b) of this sectionfi, you
must allocate any amount paid by the
consumer in excess of the required
minimum periodic payment among the
balances using one of the following
methods:
fl(1)fi ø(a)¿ High-to-low method.
The amount paid by the consumer in
excess of the required minimum
periodic payment is allocated first to the
balance with the highest annual
percentage rate and any remaining
portion to the other balances in
descending order based on the
applicable annual percentage rate.
fl(2)fi ø(b)¿ Pro rata method. The
amount paid by the consumer in excess
of the required minimum periodic
payment is allocated among the
balances in the same proportion as each
balance bears to the total balance.
fl(b) Special rule for accounts subject
to certain promotional programs. When
a promotional program provides that a
consumer will not be obligated to pay
interest that accrues on a balance if that
balance is paid in full prior to the
expiration of a specified period of time,
you must allocate amounts paid by the
consumer in excess of the required
minimum periodic payment first to that
balance during the two billing cycles
immediately preceding expiration of the
specified period and any remaining
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portion to the other balances consistent
with paragraph (a) of this section.fi
2. Section 535.24 is amended by
revising paragraph (b) to read as follows:
§ 535.24 Unfair increases in annual
percentage rates.
*
*
*
*
*
(b) Exceptions. The prohibition in
paragraph (a) of this section on
increasing annual percentage rates does
not apply where an annual percentage
rate may be increased pursuant to one
of the exceptions in this paragraph.
(1) Account opening disclosure
exception. An annual percentage rate for
a category of transactions may be
increased to flan annual percentage
ratefi øa rate¿ disclosed at account
opening upon expiration of a period of
time disclosed at account opening.
flThis exception does not permit
application of an increased annual
percentage rate disclosed at account
opening that is contingent on a
particular event or occurrence or that
may be applied at your discretion.fi
(2) Variable rate exception. An annual
percentage rate for a category of
transactions that varies according to an
index that is not under your control and
is available to the general public may be
increased due to an increase in the
index.
(3) Advance notice exception. An
annual percentage rate for a category of
transactions may be increased pursuant
to a notice under 12 CFR 226.9fl(b), (c),
or (g)fi ø(c) or (g)¿fl, provided that:
(i) If you disclose the increased rate
pursuant to 12 CFR 226.9(b), that rate
must not be applied to transactions that
occurred prior to provision of the
notice;
(ii) If you disclose the increased rate
pursuant to 12 CFR 226.9(c) or (g), that
rate must not be applied to transactions
that occurred within seven days after
provision of the notice; and
(iii) This exception does not permit an
increase in any annual percentage rate
during the first year after the account is
opened.fi øfor transactions that occur
more than seven days after provision of
the notice. This exception does not
permit an increase in any annual
percentage rate during the first year after
the account is opened.¿
(4) Delinquency exception. An annual
percentage rate may be increased due to
your not receiving the consumer’s
required minimum periodic payment
within 30 days after the due date for
that payment.
(5) Workout fland temporary
hardshipfi arrangement exception. An
annual percentage rate may be increased
due to the consumer’s flcompletion
offi øfailure to comply with the terms
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22:39 May 04, 2009
Jkt 217001
of¿ a workout flor temporary
hardshipfi arrangement between you
and the consumer flor the consumer’s
failure to comply with the terms of such
an arrangementfi, provided that the
annual percentage rate applicable to a
category of transactions following any
such increase does not exceed the rate
that applied to that category of
transactions prior to commencement of
the øworkout¿ arrangement.
fl(6) Servicemembers Civil Relief Act
exception. An annual percentage rate
that has been decreased pursuant to 50
U.S.C. app. 527 may be increased once
that provision no longer applies,
provided that the annual percentage rate
applicable to a category of transactions
following any such increase does not
exceed the rate that applied to that
category of transactions prior to the
decrease.fi
*
*
*
*
*
3. In Appendix A to Part 535:
A. Add Section 535.21—Definitions.
B. Under Section 535.22—Unfair Acts
or Practices Regarding Time to Make
Payment, under 22(b) Compliance with
General Rule, paragraph 3. is revised.
C. Under Section 535.23—Unfair Acts
or Practices Regarding Allocation of
Payments:
(i) Paragraph 2., the heading of
paragraph 3., and paragraphs 4. and 6.
are revised;
(ii) Redesignate 23(a) High-to-Low
Method as 23(a)(1) High-to-Low Method;
(iii) Under 23(a)(1) High-to-Low
Method, paragraph 1.v. is added;
(iv) Redesignate 23(b) Pro Rata
Method as 23(a)(2) Pro Rata Method;
(v) Under 23(a)(2) Pro Rata Method,
paragraph 1. is revised; and
(vi) Add 23(b) Special Rule for
Accounts Subject to Certain
Promotional Programs.
D. Under Section 535.24—Unfair Acts
or Practices Regarding Increases in
Annual Percentage Rates:
(i) Paragraph 1. is revised;
(ii) Add paragraphs 2., 3., 4.;
(iii) Under 24(a) General Rule,
paragraphs 1., 2.i. introductory text,
2.iii. introductory text, and 2.iii.C. are
revised, and paragraph 2.iv. is added;
(iv) Under 24(b) Exceptions, add
paragraph 1.;
(v) Under 24(b)(1) Account Opening
Disclosure Exception, paragraph 1.
introductory text is revised, paragraph
1.iii. and paragraph 2. are removed,
paragraph 3. is redesignated as
paragraph 2., the introductory text of
newly designated paragraph 2. is
revised, and paragraph 2.ii. is added;
(vi) Under 24(b)(2) Variable Rate
Exception, the heading of paragraph 5.
is revised;
PO 00000
Frm 00019
Fmt 4701
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(vii) Under 24(b)(3) Advance Notice
Exception, paragraphs 2. and 3. are
revised and paragraph 4. is added;
(viii) Revise 24(b)(5) Workout
Arrangement Exception;
(ix) Under 24(c) Treatment of
Protected Balances, under 24(c)(1)
Repayment, under Paragraph 24(c)(1)(i),
the heading of paragraph 2. is revised;
and
(x) Under 24(c) Treatment of
Protected Balances, under 24(c)(2) Fees
and Charges, paragraph 1. is revised.
E. Under Section 535.25—Unfair
Balance Computation Method, under
25(a) General Rule, paragraph 3. is
revised.
Appendix A to Part 535—Official Staff
Commentary
*
*
*
*
*
Subpart C—Consumer Credit Card
Account Practices
fl§ 535.21—Definitions
21(a)
Annual Percentage Rate
1. Use of ‘‘rate.’’ For purposes of Subpart
C, ‘‘rate’’ has the same meaning as ‘‘annual
percentage rate’’ unless otherwise specified.
21(c) Consumer Credit Card Account
1. Closed accounts. If a consumer credit
card account with an outstanding balance is
closed, the account continues to be the same
consumer credit card account for purposes of
Subpart C with respect to that balance. For
example, if a savings association or a
consumer closes a consumer credit card
account with an outstanding balance, the
savings association would still be prohibited
from increasing the annual percentage rate
that applies to that balance unless permitted
by one of the exceptions in § 535.24(b).
2. Acquired accounts. If, through merger or
acquisition (for example), a savings
association acquires a consumer credit card
account with an outstanding balance, the
account continues to be the same consumer
credit card account for purposes of Subpart
C with respect to that balance. For example,
if a consumer credit card account has a
$1,000 purchase balance with an annual
percentage rate of 15% and the savings
association that acquires that account applies
an 18% rate to purchases, the savings
association would be prohibited from
applying the 18% rate to the $1,000 balance
unless permitted by one of the exceptions in
§ 535.24(b).
3. Balance transfers.
i. Between accounts issued by the same
savings association. If a balance is transferred
from a consumer credit card account issued
by a savings association to another credit
account issued by the same savings
association or its affiliate or subsidiary, the
account continues to be the same consumer
credit card account for purposes of Subpart
C with respect to that balance unless the
account to which the balance is transferred
is an open-end credit plan secured by the
consumer’s dwelling. For example, if a
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consumer credit card account has a $2,000
purchase balance with an annual percentage
rate of 15% and that balance is transferred to
another consumer credit card account issued
by the same savings association that applies
an 18% rate to purchases, the savings
association would be prohibited from
applying the 18% rate to the $2,000 balance
unless permitted by one of the exceptions in
§ 535.24(b). Additional circumstances in
which a balance is considered transferred for
purposes of this comment include when:
A. A retail credit card with an outstanding
balance is replaced or substituted with a
cobranded general purpose card that can be
used with a broader merchant base;
B. A credit card account with an
outstanding balance is replaced or
substituted with another credit card account
offering different features;
C. A credit card account with an
outstanding balance is consolidated or
combined with one or more other credit card
accounts into a single credit card account;
and
D. A credit card account is replaced or
substituted with a line of credit that can be
accessed solely by an account number.
ii. Between accounts issued by different
institutions. If a balance is transferred to a
consumer credit card account issued by a
savings association from a credit account
issued by a different savings association or an
institution that is not an affiliate or
subsidiary of the savings association that
issued the consumer credit card account, the
provisions of Subpart C do not prohibit the
savings association to which the balance is
transferred from applying its account terms
to that balance, provided that those terms
comply with Subpart C. For example, if a
consumer credit card account issued by
savings association A has a $1,000 purchase
balance at an annual percentage rate of 15%
and the consumer transfers that balance to a
consumer credit card account with a
purchase rate of 17% issued by savings
association B, savings association B may
apply the 17% rate to the $1,000 balance.
However, savings association B may not
subsequently increase the rate on that
balance unless permitted by one of the
exceptions in § 535.24(b).fi
§ 535.22—Unfair Time To Make Payment
*
22(b)
*
*
*
*
*
Compliance With General Rule
*
*
*
*
3. Example of alternative method of
compliance. Assume that, for a particular
type of consumer credit card account, a
savings association only provides periodic
statements electronically and only accepts
payments electronically (consistent with
applicable law and regulatory guidancefl,
including the consumer notice and consent
procedures of the Electronic Signatures in
Global and National Commerce Act (E-Sign
Act), 15 U.S.C. 7001 et seq.fi). Under these
circumstances, the savings association could
comply with § 535.22(a) even if it does not
provide periodic statements 21 days before
the payment due date consistent with
§ 535.22(b)(2).
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22:39 May 04, 2009
Jkt 217001
§ 535.23—Unfair Allocation of Payments
*
*
*
*
*
2. Adjustments of one dollar or less
permitted. When allocating payments, the
savings association may adjust amounts by
one dollar or less. For example, if a savings
association is allocating $100 pursuant to
§ 535.23fl(a)(2)fiø(b)¿ among balances of
$1,000, $2,000, and $4,000, the savings
association may apply $14 to the $1,000
balance, $29 to the $2,000 balance, and $57
to the $4,000 balance.
3. Applicable balances and [annual
percentage] rates. * * *
4. Use of permissible allocation methods.
A savings association is not prohibited from
changing the allocation method for a
consumer credit card account or from using
different allocation methods for different
consumer credit card accounts, so long as the
methods used are consistent with § 535.23.
For example, a savings association may
change from allocating to the highest rate
balance first pursuant to § 535.23(a)fl(1)fi
to allocating pro rata pursuant to
§ 535.23fl(a)(2)fiø(b)¿ or vice versa.
Similarly, a savings association may allocate
to the highest rate balance first pursuant to
§ 535.23(a)fl(1)fi on some of its accounts
and allocate pro rata pursuant to
§ 535.23fl(a)(2)fiø(b)¿ on other accounts.
*
*
*
*
*
6. Balances with the same [annual
percentage] rate. When the same annual
percentage rate applies to more than one
balance on an account and a different annual
percentage rate applies to at least one other
balance on that account, § 535.23
flgenerallyfi does not require that any
particular method be used when allocating
among the balances with the same annual
percentage rate. Under these circumstances,
a savings association may treat the balances
with the same rate as a single balance or
separate balances. See comments
23(a)fl(1)fi–1.iv and 23fl(a)(2)fiø(b)¿–2.iv.
flHowever, when a consumer will not be
obligated to pay interest that accrues on a
balance if that balance is paid in full prior
to the expiration of a specified period of
time, that balance must be treated as a
balance with an annual percentage rate of
zero for purposes of § 535.23 during that
period of time. For example, if an account
has a $1,000 purchase balance and a $2,000
balance on which the consumer will not be
obligated to pay interest if that balance is
paid in full prior to July 1 and a 15% annual
percentage rate applies to both, the balances
must be treated as balances with different
rates for purposes of § 535.23 until July 1. In
addition, for purposes of allocating pursuant
to § 535.23(a)(1), any amount paid by the
consumer in excess of the required minimum
periodic payment must be applied first to the
$1,000 purchase balance except during the
last two billing cycles of the promotional
period (when it must be applied first to any
remaining portion of the $2,000 balance). See
comment 23(a)(1)–1.v.fi
23(a)fl(1)fi High-to-Low Method
1. * * *
flv. Assume that on January 1 a consumer
uses a credit card account to make a $1,200
purchase subject to a promotional offer under
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Frm 00020
Fmt 4701
Sfmt 4700
which interest accrues at an annual
percentage rate of 15% but the consumer will
not be obligated to pay that interest if the
balance is paid in full on or before June 30.
The billing cycles for this account begin on
the first day of the month and end on the last
day of the month. Each month from January
through June, the consumer uses the account
to make $200 in purchases that are not
subject to the promotional offer but are
subject to the 15% rate. Each month from
February through June, the consumer pays
$400 in excess of the required minimum
periodic payment on the payment due date,
which is the twenty-fifth of the month. Any
interest that accrues on the non-promotional
purchases is paid by the required minimum
periodic payment. A savings association
using this method would allocate the $400
excess payments received on February 25,
March 25, and April 25 as follows: $200 to
pay off the non-promotional balance (that is
subject to the 15% rate) and the remaining
$200 to the promotional balance (that is
treated as a balance with a rate of zero).
Section 535.23(b), however, requires the
savings association to allocate the entire $400
excess payment received on May 25 to the
promotional balance. Similarly, § 535.23(b)
requires the savings association to allocate
the $400 excess payment received on June 25
as follows: $200 to the promotional balance
(which pays that purchase in full) and the
remaining $200 to the non-promotional
balance.fi
23fl(a)(2)fiø(b)¿ Pro Rata Method
1. Total balance. A savings association
may, but is not required to, deduct amounts
paid by the consumer’s required minimum
periodic payment when calculating the total
balance for purposes of
§ 535.23fl(a)(2)fiø(b)(3)¿. See comment
23fl(a)(2)fiø(b)¿–2.iii.
*
*
*
*
*
fl23(b) Special Rule for Accounts Subject
to Certain Promotional Programs
1. Grace periods. Section 535.23(b) applies
to promotional programs under which the
consumer is not obligated to pay interest that
accrues on a balance if that balance is paid
in full prior to the expiration of a specified
period of time. A grace period during which
a consumer may repay one or more balances
on a consumer credit card account is not a
‘‘promotional program’’ for purposes of
§ 535.23(b).fi
§ 535.24—Unfair Increases in Annual
Percentage Rates
1. Relationship to Regulation Z, 12 CFR
part 226. A savings association that complies
with the applicable disclosure requirements
in Regulation Z, 12 CFR part 226, has
complied with the disclosure requirements in
§ 535.24. See 12 CFR 226.5a, 226.6, 226.9.
For example, a savings association may
comply with the requirement in § 535.24(a)
to disclose at account opening the annual
percentage rates that will apply to each
category of transactions by complying with
the disclosure requirements in 12 CFR 226.5a
regarding applications and solicitations and
the requirements in 12 CFR 226.6 regarding
account-opening disclosures. Similarly, in
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order to increase an annual percentage rate
on new transactions pursuant to
§ 535.24(b)(3), a savings association must
comply with the disclosure requirements in
12 CFR 226.9fl(b), (c), or (g)fiø(c) or (g)¿.
However, nothing in § 535.24 alters the
requirements in 12 CFR 226.9(c) and (g) that
creditors provide consumers with written
notice at least 45 days prior to the effective
date of certain increases in the annual
percentage rates on open-end (not homesecured) credit plans.
fl2. Relationship to grace period. Nothing
in § 535.24 prohibits a savings association
from assessing interest due to the loss of a
grace period to the extent consistent with
§ 535.25. In addition, a savings association
has not reduced an annual percentage rate on
a consumer credit account for purposes of
§ 535.24 if the savings association does not
charge interest on a balance when the
consumer pays that balance in full prior to
the expiration of a grace period.
3. Category of transactions. For purposes of
§ 535.24, a ‘‘category of transactions’’ is a
type or group of transactions to which an
annual percentage rate applies that is
different than the annual percentage rate that
applies to other transactions. For example,
purchase transactions, cash advance
transactions, and balance transfer
transactions are separate categories of
transactions for purposes of § 535.24 if a
savings association applies different annual
percentage rates to each. Furthermore, if, for
example, the savings association applies
different annual percentage rates to different
types of purchase transactions (such as one
rate for purchases of gasoline and a different
rate for all other purchases), each type
constitutes a separate category of transactions
for purposes of § 535.24.
4. Account opening.
i. Multiple accounts with same savings
association. When a consumer has a credit
card account with a savings association and
the consumer opens a new credit card
account with the same savings association (or
its affiliate or subsidiary), the opening of the
new account constitutes an ‘‘account
opening’’ for purposes of § 535.24 if, more
than 15/30 days after the new account is
opened, the consumer has the ability to
obtain additional extensions of credit on each
account. For example, assume that, on
January 1 of year one, a consumer opens a
credit card account with a savings
association. On July 1 of year one, the
consumer opens a second credit card account
with that savings association. On July 15, a
$1,000 balance is transferred from the first
account to the second account. The opening
of the second account constitutes the opening
of an account for purposes of § 535.24 so long
as, on July 17/August 1, the consumer can
engage in transactions using either account.
Under these circumstances, the savings
association could not increase an annual
percentage rate on the second account
pursuant to § 535.24(b)(3) until July 1 of year
two (which is one year after the second
account was opened).
ii. Replacement or consolidation.
A. Generally. A consumer credit card
account has not been opened for purposes of
§ 535.24 when a consumer credit card
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account issued by a savings association is
replaced or consolidated with another
consumer credit card account issued by the
same savings association (or its affiliate or
subsidiary). Circumstances in which a
consumer credit card account has not been
opened for purposes of § 535.24 include
when:
(1) A retail credit card is replaced with a
cobranded general purpose card that can be
used at a wider number of merchants;
(2) A credit card account is replaced with
another consumer credit card account
offering different features;
(3) A credit card account is consolidated or
combined with one or more other credit card
accounts into a single credit card account; or
(4) A credit card account acquired through
merger or acquisition is replaced with a
credit card account issued by the acquiring
institution.
B. Limitation. A savings association that
replaces or consolidates a consumer credit
card account with another consumer credit
card account issued by the savings
association (or its affiliate or subsidiary) may
not increase an annual percentage rate in a
manner otherwise prohibited by § 535.24. For
example, assume that, on January 1 of year
one, a consumer opens a consumer credit
card account with an annual percentage rate
for purchases of 15%. On July 1 of year one,
the account is replaced with a consumer
credit card account that offers different
features (such as rewards on purchases).
Under these circumstances, the savings
association cannot increase the annual
percentage rate for purchases to a rate that is
higher than 15% pursuant to § 535.24(b)(3)
until January 1 of year two (which is one year
after the first account was opened).fi
24(a) General Rule
1. Rates that will apply to each category of
transactions. Section 535.24(a) requires
savings associations to disclose, at account
opening, the annual percentage rates that will
apply to each category of transactions on the
account. A savings association cannot satisfy
this requirement by disclosing at account
opening only a range of rates or that a rate
will be ‘‘up to’’ a particular amount. flThe
disclosure requirements in § 535.24(a) do not
apply to annual percentage rates that are
contingent on a particular event or
occurrence or may be applied at the savings
association’s discretion (such as penalty
rates) insofar as those rates may be applied
consistent with § 535.24.fi
2. * * *
i. Assume that, at account opening on
January 1 of year one, a savings association
discloses that the annual percentage rate for
purchases is a non-variable rate of 15% and
will apply for six months. The savings
association also discloses that, after six
months, the annual percentage rate for
purchases will be a variable rate that is
currently 18% and will be adjusted quarterly
by adding a margin of 8 percentage points to
a publicly available index not under the
savings association’s control.
flFurthermore,fi øFinally,¿ the savings
association discloses that the annual
percentage rate for cash advances is the same
variable rate that will apply to purchases
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after six months. flFinally, the savings
association discloses that, to the extent
consistent with § 535.24 and other applicable
law, a non-variable penalty rate of 30% may
apply if the consumer makes a late
payment.fi The payment due date for the
account is the twenty-fifth day of the month
and the required minimum periodic
payments are applied to accrued interest and
fees but do not reduce the purchase and cash
advance balances.
*
*
*
*
*
iii. Assume that, at account opening on
January 1 of year one, a savings association
discloses that the annual percentage rate for
purchases is a variable rate determined by
adding a margin of 6 percentage points to a
publicly-available index outside of the
savings association’s control. The savings
association also discloses that, to the extent
consistent with § 535.24 and other applicable
law, a non-variable penalty rate of 28% may
apply if the consumer makes a late payment.
The due date for the account is the fifteenth
of the month. On May 30 of year two, the
account has a purchase balance of $1,000. On
May 31, the creditor provides a notice
pursuant to 12 CFR 226.9(c) informing the
consumer of a new variable rate that will
apply on July 16 for all purchases made on
or after June 8 (calculated by using the same
index and an increased margin of 8
percentage points). On June 7, the consumer
makes a $500 purchase. On June 8, the
consumer makes a $200 purchase. On June
25, the savings association has not received
the payment due on June 15 and provides the
consumer with a notice pursuant to 12 CFR
226.9(g) stating that the penalty rate of 28%
will apply as of August 9 to all transactions
made on or after July 3 fland that, if the
consumer becomes more than 30 days late,
the penalty rate will apply to all balances on
the accountfi. On July 4, the consumer
makes a $300 purchase.
*
*
*
*
*
C. Same facts as paragraph A. above except
the payment due on June 15 of year two is
received on July 20. Section 535.24(b)(4)
permits the savings association to apply the
28% penalty rate to all balances on the
account and to future transactions because it
has not received payment within 30 days
after the due date. Because the savings
association provided a 12 CFR 226.9(g) notice
on June fl25fiø24¿ stating the 28% penalty
rate, the savings association may apply the
28% penalty rate to all balances on the
account as well as any future transactions on
August 9 without providing an additional
notice pursuant to 12 CFR 226.9(g).
fliv. Assume that, at account opening on
January 1 of year one, the savings association
discloses a promotional program under
which interest on purchases made during
January will accrue at a non-variable rate of
20%, but the consumer will not be obligated
to pay that interest if those purchases are
paid in full by December 31 of year one. On
January 15, the consumer makes a purchase
of $2,000. No other transactions are made on
the account. The payment due on April 1 is
not received until April 10. Section 535.24
does not permit the savings association to
deny the consumer the opportunity to avoid
interest charges on the $2,000 purchase by
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paying that purchase in full on or before
December 31 of year one. If, however, the
$2,000 purchase remains unpaid on January
1 of year two, § 535.24 does not prohibit the
savings association from charging the interest
accrued on that purchase during year one.fi
24(b) Exceptions
fl1. Delayed implementation of rate
increase. If § 535.24(b) permits a savings
association to apply an increased annual
percentage rate on a date that is not the first
day of a billing cycle, the savings association
may delay application of the increased rate
until the first day of the following billing
cycle without relinquishing the ability to
apply that rate. For example, assume that, at
account opening on January 1, a savings
association discloses that a non-variable
annual percentage rate of 10% will apply to
purchases for six months and a non-variable
rate of 15% will apply thereafter. The first
day of the billing cycle for the account is the
fifteenth of the month. If the six-month
period expires on July 1, the savings
association may delay application of the 15%
rate until July 15 without relinquishing its
ability to apply that rate under
§ 535.24(b)(1).fi
24(b)(1) Account Opening Disclosure
Exception
1. Prohibited increases in rate. Section
§ 535.24(b)(1) permits an increase in the
annual percentage rate for a category of
transactions to a rate disclosed at account
opening upon expiration of a period of time
that was also disclosed at account opening.
Section 535.24(b)(1) does not permit
application of flan increased annual
percentage ratefi øincreased rates that are¿
disclosed at account opening flthat isfi
øbut are¿ contingent on a particular event or
occurrence or flthatfi may be applied at the
savings association’s discretion. The
following examples illustrate rate increases
that are not permitted by § 535.24ø(a)¿:
*
*
*
*
*
øiii. Assume that a savings association
discloses at account opening on January 1 of
year one that interest on purchases will be
deferred for one year, although interest will
accrue on purchases during that year at a
non-variable rate of 20%. The savings
association further discloses that, if all
purchases made during year one are not paid
in full by the end of that year, the savings
association will begin charging interest on
the purchase balance and new purchases at
20% and will retroactively charge interest on
the purchase balance at a rate of 20% starting
on the date of each purchase made during
year one. On January 1 of year one, the
consumer makes a purchase of $1,500. No
other transactions are made on the account.
On January 1 of year two, $500 of the $1,500
purchase remains unpaid. Section 535.24
does not permit the savings association to
reach back to charge interest on the $1,500
purchase from January 1 through December
31 of year one. However, the savings
association may apply the previouslydisclosed 20% rate to the $500 purchase
balance beginning on January 1 of year two
(pursuant to § 535.24(b)(1)).¿
ø2. Loss of grace period. Nothing in
§ 535.24 prohibits a savings association from
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Jkt 217001
assessing interest due to the loss of a grace
period to the extent consistent with
§ 535.25.¿
fl2.fi ø3.¿ Application of rate that is
lower than disclosed rate. Section
§ 535.24(b)(1) permits an increase in the
annual percentage rate for a category of
transactions to a rate disclosed at account
opening upon expiration of a period of time
that was also disclosed at account opening.
Nothing in § 535.24 prohibits a savings
association from applying a rate that is lower
than flafi øthe¿ disclosed rate fleither
during orfi upon expiration of the period.
However, flonce thefi øif a¿ lower rate is
applied to an existing balance, the savings
association cannot subsequently increase the
rate on that balance unless it øhas¿ provided
the consumer with advance notice of the
increase pursuant to 12 CFR 226.9fl(b)fi or
(c). flThis notice must state the period of
time during which the lower rate will apply
and the rate that will apply after expiration
of that period.fi Furthermore, fla savings
association that applies a lower rate to
transactions that occurred during the first
year after account opening may not
subsequently increase the rate that applies to
those transactions to a rate that is higher than
the increased rate disclosed at account
openingfi øthe savings association cannot
increase the rate on that existing balance to
a rate that is higher than the increased rate
disclosed at account opening¿. The following
flexamples illustratefi øexample
illustrates¿ the application of flthefi øthis¿
rule:
*
*
*
*
*
flii. Assume that a savings association
discloses at account opening on January 1 of
year one that a non-variable annual
percentage rate of 15% will apply to
purchases for one year, after which that rate
will increase to a non-variable rate of 18%.
The savings association also discloses that, to
the extent consistent with § 535.24 and other
applicable law, a non-variable penalty rate of
30% may apply if the consumer’s required
minimum periodic payment is received after
the payment due date, which is the tenth of
the month. The required minimum periodic
payments are applied to accrued interest and
fees but do not reduce the purchase balance.
A. On September 30 of year one, the
account has a purchase balance of $1,400 at
the 15% rate. On October 1, the savings
association provides a notice pursuant to 12
CFR 226.9(c) informing the consumer that the
rate for new purchases will decrease to a
non-variable rate of 10% for six months (from
October 1 through March 31 of year two) and
that, beginning on April 1 of year two, the
rate for purchases will increase to a nonvariable rate of 20%. The savings association
does not apply the 10% rate to the $1,400
purchase balance. On October 15 of year one,
the consumer makes a $300 purchase at the
10% rate. On January 1 of year two, the
savings association may begin accruing
interest on the $1,400 purchase balance at
18% (as disclosed at account opening). On
January 15 of year two, the consumer makes
a $150 purchase at the 10% rate. On April
1 of year two, the 10% rate that applies to
the $300 purchase and the $150 purchase
expires. The savings association may begin
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Sfmt 4700
accruing interest on the $150 purchase at
20% (as disclosed in the 12 CFR 226.9(c)
notice). Because, however, the $300 purchase
occurred during the first year after account
opening, the savings association cannot
increase the rate that applies to that purchase
to a rate that is higher than the 18% rate
disclosed at account opening.
B. Same facts as above except that the
required minimum periodic payment due on
November 10 of year one is not received until
November 15. Section 535.24(b)(1) does not
permit the savings association to increase any
annual percentage rate on the account at this
time. The savings association may, however,
apply the 30% penalty rate to new
transactions beginning on January 1 of year
two pursuant to § 535.24(b)(3) by providing
a 12 CFR 226.9(g) notice informing the
consumer of this increase no later than
November 16 of year one. On January 1 of
year two, § 535.24(b)(1) permits the savings
association to begin accruing interest on the
$1,400 purchase balance at 18% (as disclosed
at account opening). If the consumer makes
the $150 purchase on January 15 of year two,
§ 535.24(b)(3) would permit the savings
association to apply the 30% rate to that
purchase. On April 1 of year two, the 10%
rate that applies to the $300 purchase
expires. Because this purchase occurred
during the first year after account opening,
the savings association cannot increase the
rate that applies to that purchase to a rate
that is higher than the 18% rate disclosed at
account opening.fi
24(b)(2)
*
*
Variable Rate Exception
*
*
*
5. Changing a variable øannual
percentage¿ rate to a non-variable øannual
percentage¿ rate. * * *
*
*
24(b)(3)
*
*
*
*
*
Advance Notice Exception
*
*
*
2. Transactions that floccurred prior to
provision of notice or within seven days after
provision of noticefi øoccur more than seven
days after notice provided¿. flSection
535.24(b)(3) generally permits a savings
association to apply an increased rate to
transactions that occur after provision of a 12
CFR 226.9(b) notice or more than seven days
after provision of a 12 CFR 226.9(c) or (g)
notice. If a rate increase is disclosed pursuant
to both 12 CFR 226.9(b) and 12 CFR 226.9(c),
that rate may only be applied to transactions
that occur more than seven days after
provision of the 12 CFR 226.9(c) notice.
Section 535.24(b)(3) does not permit a
savings association to reach back to days
before the effective date of the rate increase
under 12 CFR 226.9(c) or (g) when
calculating interest charges. See comment
24(b)(3)–3.fi øSection 535.24(b)(3) generally
prohibits a savings association from applying
an increased rate to transactions that occur
within seven days after provision of the 12
CFR 226.9 (c) or (g) notice.¿ flWhether a
transaction occurred prior to provision of a
notice or within seven days after provision of
a notice is determined by the date of the
transaction. In some cases, however, a
merchant may place a ‘‘hold’’ on the
available credit on an account for an
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estimated transaction amount when the
actual transaction amount will not be known
until a later date. In these circumstances, the
date of the transaction for purposes of
§ 535.24(b)(3) is the date on which the
merchant determines the actual transaction
amount. For example, assume that, when a
consumer uses a credit card account to check
into a hotel on July 1, the hotel obtains
authorization for a $750 hold on the account
to ensure there is adequate available credit to
cover the anticipated cost of the stay. When
the consumer checks out on July 4, the actual
cost of the stay is $850 because of additional
incidental costs, and the hotel charges this
amount to the account. For purposes of
§ 535.24(b)(3), the transaction occurred on
July 4.fi øThis prohibition does not,
however, apply to transactions that are
authorized within seven days after provision
of the 12 CFR 226.9 (c) or (g) notice but are
settled more than seven days after the notice
was provided.¿
3. Examples.
i. Assume that a consumer credit card
account is opened on January 1 of year one.
On March 14 of year two, the account has a
purchase balance of $2,000 at a non-variable
annual percentage rate of 15%. On March 15,
the savings association provides a notice
pursuant to 12 CFR 226.9(c) informing the
consumer that the rate for new purchases
will increase to a non-variable rate of 18% on
May 1. The notice further states that the 18%
rate will apply for six months (until
November 1) and states that thereafter the
savings association will apply a variable rate
that is currently 22% and is determined by
adding a margin of 12 percentage points to
a publicly-available index that is not under
the savings association’s control. The seventh
day after provision of the notice is March 22
and, on that date, the consumer makes a $200
purchase. On March 24, the consumer makes
a $1,000 purchase. On May 1, § 535.24(b)(3)
permits the savings association to begin
accruing interest at 18% on the $1,000
purchase made on March 24. The savings
association is not permitted to apply the 18%
rate to the $2,200 purchase balance as of
March 22. After six months (November 2),
the savings association may begin accruing
interest on any remaining portion of the
$1,000 purchase at the previously-disclosed
variable rate determined using the 12-point
margin.
øii. Same facts as above except that the
$200 purchase is authorized by the savings
association on March 22 but is not settled
until March 23. On May 1, § 535.24(b)(3)
permits the savings association to start
charging interest at 18% on both the $200
purchase and the $1,000 purchase. The
savings association is not permitted to apply
the 18% rate to the $2,000 purchase balance
as of March 22.¿
flii.fi øiii.¿ Same facts as øin paragraph
i.¿ above except that on September 17 of year
two (which is 45 days before expiration of
the 18% non-variable rate), the savings
association provides a notice pursuant to 12
CFR 226.9(c) informing the consumer that, on
November 2, a new variable rate will apply
to new purchases and any remaining portion
of the $1,000 balance (calculated by using the
same index and a reduced margin of 10
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22:39 May 04, 2009
Jkt 217001
percentage points). The notice further states
that, on May 1 of year three, the margin will
increase to the margin disclosed flin the
March 15 noticefi øat account opening¿ (12
percentage points). On May 1 of year three,
§ 535.24(b)(3) permits the savings association
to increase the margin used to determine the
variable rate that applies to new purchases to
12 percentage points and to apply that rate
to any remaining portion of the $1,000
purchase as well as to new purchases. øSee
comment 24(b)(1)–3.¿ The savings
association is not permitted to apply this rate
to any remaining portion of the $2,200
purchase balance as of March 22.
fl4. Application of a lower rate. Nothing
in § 535.24 prohibits a savings association
from lowering the annual percentage rate that
applies to an existing balance or to new
transactions. However, once the lower rate is
applied to an existing balance, the savings
association cannot subsequently increase the
rate on that balance unless it provided the
consumer with advance notice of the increase
pursuant to 12 CFR 226.9(b) or (c). This
notice must state the period of time during
which the lower rate will apply and the rate
that will apply after expiration of that period.
Furthermore, a savings association that
applies a decreased rate to transactions that
occurred prior to provision of the notice—or,
in the case of a 12 CFR 226.9(c) or (g) notice,
transactions that occurred within seven days
after provision of the notice—may not
subsequently increase the rate that applies to
those transactions to a rate that is higher than
the rate that applied prior to the decrease.
The following examples illustrate the
application of the rule:
i. Assume that a savings association
discloses at account opening on January 1 of
year one that a non-variable annual
percentage rate of 10% will apply to
purchases for one year, after which that rate
will increase to a non-variable rate of 15%.
The savings association also discloses that, to
the extent consistent with § 535.24 and other
applicable law, a non-variable penalty rate of
30% may apply if the consumer’s required
minimum periodic payment is received after
the payment due date, which is the tenth of
the month. The required minimum periodic
payments are applied to accrued interest and
fees but do not reduce the purchase balance.
On June 30 of year two, the account has a
purchase balance of $1,000 at the 15% rate.
On July 1, the savings association provides a
notice pursuant to 12 CFR 226.9(c) informing
the consumer that the rate for new purchases
will decrease to a non-variable rate of 5% for
six months (from July 1 through December 31
of year two) and that, beginning on January
1 of year three, the rate for purchases will
increase to a non-variable rate of 17%. On
July 8 of year two, the consumer makes a
$200 purchase. On July 9, the consumer
makes a $100 purchase. On January 1 of year
three, § 535.24(b)(3) permits the savings
association to begin accruing interest on the
$100 purchase at 17%. The savings
association may not apply the 17% rate to the
$200 purchase because that transaction
occurred within seven days after provision of
the 12 CFR 226.9(c) notice. If the savings
association applied the 5% rate to the $1,000
purchase balance and the $200 purchase, the
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20825
savings association may not increase the rate
that applies to those amounts to a rate that
is higher than 15% on January 1 of year
three.
ii. Same facts as above except that the
required minimum periodic payment due on
September 10 of year two is not received
until September 15 of year two. On
September 15 of year two, the savings
association provides a notice pursuant to 12
CFR 226.9(g) informing the consumer that the
rate for new purchases will increase to the
30% penalty rate on October 31. On October
31, § 535.23(b)(3) permits the savings
association to begin accruing interest at 30%
on any purchase made on or after September
23. The savings association may not,
however, apply the 30% rate to the $1,300 in
purchases. Instead, the savings association
must continue to apply the 5% rate to the
$100 purchase until at least January 1 of year
three when § 535.24(b)(3) permits the savings
association to begin accruing interest on that
purchase at 17%. Similarly, if the savings
association applied the 5% rate to the $1,000
purchase balance and the $200 purchase, the
savings association may begin accruing
interest on those amounts at 15% on January
1 of year three.
iii. Assume that a savings association
discloses at account opening on January 1 of
year one that the rate that applies to
purchases is a variable annual percentage
rate that is currently 18% and will be
adjusted quarterly by adding a margin of 8
percentage points to a publicly available
index not under the savings association’s
control. The savings association also
discloses that, to the extent consistent with
§ 535.24 and other applicable law, a nonvariable penalty rate of 30% may apply if the
consumer’s required minimum periodic
payment is received after the payment due
date, which is the first of the month. On July
30 of year two, the consumer uses the
account for a $1,000 purchase in response to
a promotional offer. Under the terms of this
offer, interest on purchases made during the
months of July through September will
accrue at the variable rate for purchases but
the consumer will not be obligated to pay
that interest if all purchases made during that
three-month period are paid in full by
December 31 of year two. The payment due
on September 1 of year two is not received
until September 6. Section 535.24 does not
permit the savings association to deny the
consumer the opportunity to avoid interest
charges on the $1,000 purchase by paying
that purchase in full on or before December
31 of year two. The savings association may,
however, provide a notice pursuant to 12
CFR 226.9(g) on September 2 of year two
informing the consumer that the promotional
offer does not apply to purchases made on or
after September 10 and that the rate for such
purchases will increase to the 30% penalty
rate on October 18. On December 31 of year
two, the $1,000 purchase has been paid in
full. Under these circumstances, the savings
association may not charge any interest
accrued on the $1,000 purchase.
iv. Assume that a savings association
discloses at account opening on January 1 of
year one that the rate that applies to cash
advances is a variable annual percentage rate
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that is currently 24% and will be adjusted
quarterly by adding a margin of 14
percentage points to a publicly available
index not under the savings association’s
control. On July 1 of year two, the savings
association provides checks that access the
account and, pursuant to 12 CFR
226.9(b)(3)(A), discloses that a promotional
rate of 15% will apply to credit extended by
use of the checks until January 1 of year
three, after which the cash advance rate
determined using the 14-point margin will
apply. On July 15 of year two, the consumer
uses one of the checks to pay for a $500
transaction. On January 1 of year three,
§ 535.24(b)(3) permits the savings association
to apply the cash advance rate determined
using the 14-point margin to the $500
transaction.fi
24(b)(5) Workout fland Temporary
Hardshipfi Arrangement Exception
1. Scope of exception. Nothing in
§ 535.24(b)(5) permits a savings association to
alter the requirements of § 535.24 pursuant to
a workout flor temporary hardshipfi
arrangement between a consumer and the
savings association. For example, a savings
association cannot increase an annual
percentage rate pursuant to a workout flor
temporary hardshipfi arrangement unless
otherwise permitted by § 535.24. In addition,
a savings association cannot require the
consumer to make payments with respect to
a protected balance that exceed the payments
permitted under § 535.24(c).
2. Variable øannual percentage¿ rates. If
the annual percentage rate that applied to a
category of transactions prior to
commencement of the workout flor
temporary hardshipfi arrangement varied
with an index consistent with § 535.24(b)(2),
the rate applied to that category of
transactions following an increase pursuant
to § 535.24(b)(5) must be determined using
the same formula (index and margin).
3. Example flsfi.
fli.fi Assume that, consistent with
§ 535.24(b)(4), the margin used to determine
a variable annual percentage rate that applies
to a $5,000 balance is increased from 5
percentage points to 15 percentage points.
Assume also that the savings association and
the consumer subsequently agree to a
workout arrangement that reduces the margin
back to 5 points on the condition that the
consumer pay a specified amount by the
payment due date each month. If the
consumer does not pay the agreed-upon
amount by the payment due date, the savings
association may increase the margin for the
variable rate that applies to the $5,000
balance up to 15 percentage points. 12 CFR
226.9 does not require advance notice of this
type of increase.
flii. Assume that a consumer fails to make
four consecutive minimum payments totaling
$480 on a consumer credit card account with
a balance of $6,000 and that, consistent with
§ 535.24(b)(4), the annual percentage rate that
applies to that balance is increased from a
non-variable rate of 15% to a non-variable
penalty rate of 30%. Assume also that the
savings association and the consumer
subsequently agree to a temporary hardship
arrangement that reduces all rates on the
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account to 0% on the condition that the
consumer pay an amount by the payment due
date each month that is sufficient to cure the
$480 delinquency within six months. If the
consumer pays the agreed-upon amount by
the payment due date during the six-month
period and cures the delinquency, the
savings association may increase the rate that
applies to any remaining portion of the
$6,000 balance to 15% or any other rate up
to the 30% penalty rate.fi
24(c)
*
Treatment of Protected Balances
*
24(c)(1)
*
*
*
*
*
Repayment
*
*
*
Paragraph 24(c)(1)(i)
*
*
*
*
*
2. Amortization when applicable øannual
percentage¿ rate is variable. * * *
*
*
*
*
*
24(c)(2) Fees and Charges
1. Fee or charge based solely on the
protected balance. A savings association is
prohibited from assessing a fee or charge
based solely on balances to which § 535.24(c)
applies. For example, a savings association is
prohibited from assessing a monthly
maintenance fee that would not be charged
if the account did not have a protected
balance. A savings association is not,
however, prohibited from flcontinuing to
assess a periodic fee that was assessed before
the account had a protected balance.fi
flSimilarly, a savings association is not
prohibited fromfi assessing fees such as late
payment fees or fees for exceeding the credit
limit even if such fees are based in part on
the protected balance flor if the only balance
on the account is a protected balancefi.
§ 535.25—Unfair Balance Computation
Method
25(a)
*
General Rule
*
*
*
*
fl3. Charging accrued interest at
expiration of certain promotional programs.
When a savings association offers a
promotional program under which a
consumer will not be obligated to pay
interest that accrues on a balance if that
balance is paid in full prior to a specified
date or expiration of a specified period of
time, § 535.25 does not prohibit the savings
association from charging that accrued
interest to the account if the balance is not
paid in full prior to the specified date
(consistent with applicable law and
regulatory guidance).fi
*
*
*
*
*
National Credit Union Administration
For the reasons discussed in the joint
preamble, the NCUA Board proposes to
further amend 12 CFR Part 706, as
amended at 74 FR 5575, January 29,
2009, as set forth below:
PART 706—UNFAIR OR DECEPTIVE
ACTS OR PRACTICES
1. The authority citation for part 706
continues to read as follows:
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Authority: 15 U.S.C. 57a.
2. Revise § 706.23 as follows:
§ 706.23
Unfair allocation of payments.
When different annual percentage
rates apply to different balances on a
consumer credit card account:
(a) General rule. Except as provided in
paragraph (b) of this section, a federal
credit union must allocate any amount
paid by a member in excess of the
required minimum periodic payment
among the balances using one of the
following methods:
(1) High-to-low method. The amount
paid by a member in excess of the
required minimum periodic payment is
allocated first to the balance with the
highest annual percentage rate and any
remaining portion to the other balances
in descending order based on the
applicable annual percentage rate.
(2) Pro rata method. The amount paid
by a member in excess of the required
minimum periodic payment is allocated
among the balances in the same
proportion as each balance bears to the
total balance.
(b) Special rule for accounts subject to
certain promotional programs. When a
promotional program provides that a
member will not be obligated to pay
interest that accrues on a balance if that
balance is paid in full prior to the
expiration of a specified period of time,
a federal credit union must allocate
amounts paid by a member in excess of
the required minimum periodic
payment first to that balance during the
two billing cycles immediately
preceding expiration of the specified
period and any remaining portion to the
other balances consistent with
paragraph (a) of this section.
3. Amend § 706.24 by revising
paragraphs (b)(1) through (b)(5) and
adding paragraph (b)(6) to read as
follows:
§ 706.24 Unfair increases in annual
percentage rates.
*
*
*
*
*
(b) * * *
(1) Account opening disclosure
exception. An annual percentage rate for
a category of transactions may be
increased to an annual percentage rate
disclosed at account opening upon
expiration of a period of time disclosed
at account opening. This exception does
not permit application of an increased
annual percentage rate disclosed at
account opening that is contingent on a
particular event or occurrence or that
may be applied at the federal credit
union’s discretion.
(2) Variable rate exception. An annual
percentage rate for a category of
transactions that varies according to an
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index that is not under the federal credit
union’s control and is available to the
general public may be increased due to
an increase in the index.
(3) Advance notice exception. An
annual percentage rate for a category of
transactions may be increased pursuant
to a notice under 12 CFR 226.9(b), (c),
or (g), provided that:
(i) If the federal credit union discloses
the increased rate pursuant to 12 CFR
226.9(b), that rate must not be applied
to transactions that occurred prior to
provision of the notice;
(ii) If the federal credit union
discloses the increased rate pursuant to
12 CFR 226.9(c) or (g), that rate must not
be applied to transactions that occurred
within seven days after provision of the
notice; and
(iii) This exception does not permit an
increase in any annual percentage rate
during the first year after an account is
opened.
(4) Delinquency exception. An annual
percentage rate may be increased due to
the federal credit union not receiving a
member’s required minimum periodic
payment within 30 days after the due
date for that payment.
(5) Workout and temporary hardship
arrangement exception. An annual
percentage rate may be increased due to
a member’s completion of a workout or
temporary hardship arrangement
between a federal credit union and the
member or a member’s failure to comply
with the terms of such an arrangement,
provided that the annual percentage rate
applicable to a category of transactions
following any such increase does not
exceed the rate that applied to that
category of transactions prior to
commencement of the arrangement.
(6) Servicemembers Civil Relief Act
exception. An annual percentage rate
that has been decreased pursuant to 50
U.S.C. app. 527 may be increased once
that provision no longer applies,
provided that the annual percentage rate
applicable to a category of transactions
following any such increase does not
exceed the rate that applied to that
category of transactions prior to the
decrease.
*
*
*
*
*
4. In Appendix A to Part 706:
A. Add Section 706.21—Definitions.
B. Under Section 706.22—Unfair Acts
or Practices Regarding Time To Make
Payment, under 22(b) Compliance with
General Rule, paragraph 3. is revised.
C. Under Section 706.23—Unfair Acts
or Practices Regarding Allocation of
Payments:
(i) Paragraph 2., the heading of
paragraph 3., and paragraphs 4. and 6.
are revised;
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(ii) Redesignate 23(a) High-to-Low
Method as 23(a)(1) High-to-Low Method;
(iii) Under 23(a)(1) High-to-Low
Method, paragraph 1.v. is added;
(iv) Redesignate 23(b) Pro Rata
Method as 23(a)(2) Pro Rata Method;
(v) Under 23(a)(2) Pro Rata Method,
paragraph 1. is revised; and
(vi) Add 23(b) Special Rule for
Accounts Subject to Certain
Promotional Programs.
D. Under Section 706.24—Unfair Acts
or Practices Regarding Increases in
Annual Percentage Rates:
(i) Paragraph 1. is revised;
(ii) Add paragraphs 2., 3., 4.;
(iii) Under 24(a) General Rule,
paragraphs 1., 2.i. introductory text,
2.iii. introductory text, and 2.iii.C. are
revised, and paragraph 2.iv. is added;
(iv) Under 24(b) Exceptions, add
paragraph 1.;
(v) Under 24(b)(1) Account Opening
Disclosure Exception, paragraph 1.
introductory text is revised, paragraph
1.iii. and paragraph 2. are removed,
paragraph 3. is redesignated as
paragraph 2., the introductory text of
newly designated paragraph 2. is
revised, and paragraph 2.ii. is added;
(vi) Under 24(b)(2) Variable Rate
Exception, the heading of paragraph 5.
is revised;
(vii) Under 24(b)(3) Advance Notice
Exception, paragraphs 2. and 3. are
revised and paragraph 4. is added;
(viii) Revise 24(b)(5) Workout
Arrangement Exception;
(ix) Under 24(c) Treatment of
Protected Balances, under 24(c)(1)
Repayment, under Paragraph 24(c)(1)(i),
the heading of paragraph 2. is revised;
and
(x) Under 24(c) Treatment of
Protected Balances, under 24(c)(2) Fees
and Charges, paragraph 1. is revised.
E. Under Section 706.25—Unfair
Balance Computation Method, under
25(a) General Rule, paragraph 3. is
revised.
Appendix A to Part 706—Official Staff
Commentary
*
*
*
*
*
Subpart C—Consumer Credit Card
Account Practices Rule
§ 706.21—Definitions
21(a)
Annual Percentage Rate
1. Use of ‘‘rate.’’ For purposes of Subpart
C, ‘‘rate’’ has the same meaning as ‘‘annual
percentage rate’’ unless otherwise specified.
21(c) Consumer Credit Card Account
1. Closed accounts. If a consumer credit
card account with an outstanding balance is
closed, the account continues to be the same
consumer credit card account for purposes of
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20827
Subpart C with respect to that balance. For
example, if a federal credit union or a
member closes a consumer credit card
account with an outstanding balance, the
federal credit union would still be prohibited
from increasing the annual percentage rate
that applies to that balance unless permitted
by one of the exceptions in § 706.24(b).
2. Acquired accounts. If, through merger or
acquisition, for example, a federal credit
union acquires a consumer credit card
account with an outstanding balance, the
account continues to be the same consumer
credit card account for purposes of Subpart
C with respect to that balance. For example,
if a consumer credit card account has a
$1,000 purchase balance with an annual
percentage rate of 12% and the federal credit
union that acquires that account applies a
15% rate to purchases, the federal credit
union would be prohibited from applying the
15% rate to the $1,000 balance unless
permitted by one of the exceptions in
§ 706.24(b).
3. Balance transfers.
i. Between accounts issued by the same
federal credit union. If a balance is
transferred from a consumer credit card
account issued by a federal credit union to
another credit account issued by the same
federal credit union, the account continues to
be the same consumer credit card account for
purposes of Subpart C with respect to that
balance unless the account to which the
balance is transferred is an open-end credit
plan secured by a member’s dwelling. For
example, if a consumer credit card account
has a $2,000 purchase balance with an
annual percentage rate of 12% and that
balance is transferred to another consumer
credit card account issued by the same
federal credit union that applies a 15% rate
to purchases, the federal credit union would
be prohibited from applying the 15% rate to
the $2,000 balance unless permitted by one
of the exceptions in § 706.24(b). Additional
circumstances in which a balance is
considered transferred for purposes of this
comment include when:
A. A retail credit card with an outstanding
balance is replaced or substituted with a
cobranded general purpose card that can be
used with a broader merchant base;
B. A credit card account with an
outstanding balance is replaced or
substituted with another credit card account
offering different features;
C. A credit card account with an
outstanding balance is consolidated or
combined with one or more other credit card
accounts into a single credit card account;
and
D. A credit card account is replaced or
substituted with a line of credit that can be
accessed solely by an account number.
ii. Between accounts issued by different
federal credit unions. If a balance is
transferred to a consumer credit card account
issued by a federal credit union from a
consumer credit card account issued by a
different financial institution that is not an
affiliate or subsidiary of the federal credit
union that issued the consumer credit card
account, the account is not the same
consumer credit card account for purposes of
Subpart C with respect to that balance. Thus,
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the provisions of Subpart C do not prohibit
the federal credit union to which the balance
is transferred from applying its account terms
to that balance, provided that those terms
comply with Subpart C. For example, if a
consumer credit card account issued by
federal credit union A has a $1,000 purchase
balance at an annual percentage rate of 13%
and a member transfers that balance to a
consumer credit card account with a
purchase rate of 15% issued by federal credit
union B, federal credit union B may apply
the 15% rate to the $1,000 balance. However,
federal credit union B may not subsequently
increase the rate on that balance unless
permitted by one of the exceptions in
§ 706.24(b).
706.22—Unfair Time To Make Payment
*
22(b)
*
*
*
*
*
Compliance With General Rule
*
*
*
*
3. Example of alternative method of
compliance. Assume that, for a particular
type of consumer credit card account, a
federal credit union only provides periodic
statements electronically and only accepts
payments electronically (consistent with
applicable law and regulatory guidance,
including the consumer notice and consent
procedures of the Electronic Signatures in
Global and National Commerce Act (E-Sign
Act), 15 U.S.C. 7001 et seq.). Under these
circumstances, the federal credit union could
comply with § 706.22(a) even if it does not
provide periodic statements 21 days before
the payment due date consistent with
§ 706.22(b)(2).
*
*
*
*
*
§ 706.23—Unfair Acts or Practices Regarding
Allocation of Payments
*
*
*
*
*
2. Adjustments of one dollar or less
permitted. When allocating payments, the
federal credit union may adjust amounts by
one dollar or less. For example, if a federal
credit union is allocating $100 pursuant to
§ 706.23(a)(2) among balances of $1,000,
$2,000, and $4,000, the federal credit union
may apply $14 to the $1,000 balance, $29 to
the $2,000 balance, and $57 to the $4,000
balance.
3. Applicable balances and rates. * * *
4. Use of permissible allocation methods.
A federal credit union is not prohibited from
changing the allocation method for a
consumer credit card account or from using
different allocation methods for different
consumer credit card accounts, so long as the
methods used are consistent with § 706.23.
For example, a federal credit union may
change from allocating to the highest rate
balance first pursuant to § 706.23(a)(1) to
allocating pro rata pursuant to § 706.23(a)(2)
or vice versa. Similarly, a federal credit
union may allocate to the highest rate
balance first pursuant to § 706.23(a)(1) on
some of its accounts and allocate pro rata
pursuant to § 706.23(a)(2) on other accounts.
*
*
*
*
*
6. Balances with the same rate. When the
same annual percentage rate applies to more
than one balance on an account and a
different annual percentage rate applies to at
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least one other balance on that account,
§ 706.23 generally does not require that any
particular method be used when allocating
among the balances with the same annual
percentage rate. Under these circumstances,
a federal credit union may treat the balances
with the same rate as a single balance or
separate balances. See comments 23(a)(1)–
1.iv and 23(a)(2)–2.iv. However, when a
member will not be obligated to pay interest
that accrues on a balance if that balance is
paid in full prior to the expiration of a
specified period of time, that balance must be
treated as a balance with an annual
percentage rate of zero for purposes of
§ 706.23 during that period of time. For
example, if an account has a $1,000 purchase
balance and a $2,000 balance on which the
member will not be obligated to pay interest
if that balance is paid in full prior to July 1
and a 15% annual percentage rate applies to
both, the balances must be treated as
balances with different rates for purposes of
§ 706.23 until July 1. In addition, for
purposes of allocating pursuant to
§ 706.23(a)(1), any amount paid by the
member in excess of the required minimum
periodic payment must be applied first to the
$1,000 purchase balance except during the
last two billing cycles of the promotional
period (when it must be applied first to any
remaining portion of the $2,000 balance). See
comment 23(a)(1)–1.v.
23(a)(1)
High-to-Low Method
1. * * *
v. Assume that on January 1 a member uses
a credit card account to make a $1,200
purchase subject to a promotional offer under
which interest accrues at an annual
percentage rate of 15% but the member will
not be obligated to pay that interest if the
balance is paid in full on or before June 30.
The billing cycles for this account begin on
the first day of the month and end on the last
day of the month. Each month from January
through June, the member uses the account
to make $200 in purchases that are not
subject to the promotional offer but are
subject to the 15% rate. Each month from
February through June, the member pays
$400 in excess of the required minimum
periodic payment on the payment due date,
which is the twenty-fifth of the month. Any
interest that accrues on the non-promotional
purchases is paid by the required minimum
periodic payment. A federal credit union
using this method would allocate the $400
excess payments received on February 25,
March 25, and April 25 as follows: $200 to
pay off the non-promotional balance (that is
subject to the 15% rate) and the remaining
$200 to the promotional balance (that is
treated as a balance with a rate of zero).
Section 706.23(b), however, requires the
federal credit union to allocate the entire
$400 excess payment received on May 25 to
the promotional balance. Similarly,
§ 706.23(b) requires the federal credit union
to allocate the $400 excess payment received
on June 25 as follows: $200 to the
promotional balance (which pays that
purchase in full) and the remaining $200 to
the non-promotional balance.
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23(a)(2) Pro Rata Method
1. Total balance. A federal credit union
may, but is not required to, deduct amounts
paid by the member’s required minimum
periodic payment when calculating the total
balance for purposes of § 706.23(a)(2). See
comment 23(a)(2)–2.iii.
*
*
*
*
*
23(b) Special Rule for Accounts Subject to
Certain Promotional Programs
1. Grace periods. Section 706.23(b) applies
to promotional programs under which the
member is not obligated to pay interest that
accrues on a balance if that balance is paid
in full prior to the expiration of a specified
period of time. A grace period during which
a member may repay one or more balances
on a consumer credit card account is not a
‘‘promotional program’’ for purposes of
§ 706.23(b).
*
*
*
*
*
§ 706.24—Unfair Increases in Annual
Percentage Rates
1. Relationship to Regulation Z, 12 CFR
part 226. A federal credit union that
complies with the applicable disclosure
requirements in Regulation Z, 12 CFR part
226, has complied with the disclosure
requirements in § 706.24. See 12 CFR 226.5a,
226.6, 226.9. For example, a federal credit
union may comply with the requirement in
§ 706.24(a) to disclose at account opening the
annual percentage rates that will apply to
each category of transactions by complying
with the disclosure requirements in 12 CFR
226.5a regarding applications and
solicitations and the requirements in 12 CFR
226.6 regarding account-opening disclosures.
Similarly, in order to increase an annual
percentage rate on new transactions pursuant
to § 706.24(b)(3), a federal credit union must
comply with the disclosure requirements in
12 CFR 226.9(b), (c), or (g). However, nothing
in § 706.24 alters the requirements in 12 CFR
226.9(c) and (g) that creditors provide
consumers with written notice at least 45
days prior to the effective date of certain
increases in the annual percentage rates on
open-end (not home-secured) credit plans.
2. Relationship to grace period. Nothing in
§ 706.24 prohibits a federal credit union from
assessing interest due to the loss of a grace
period to the extent consistent with § 706.25.
Additionally, a federal credit union has not
reduced an annual percentage rate on a
consumer credit account for purposes of
§ 706.24 if the federal credit union does not
charge interest on a balance when the
member pays that balance in full prior to the
expiration of a grace period.
3. Category of transactions. For purposes of
§ 706.24, a ‘‘category of transactions’’ is a
type or group of transactions to which an
annual percentage rate applies that is
different than the annual percentage rate that
applies to other transactions. For example,
purchase transactions, cash advance
transactions, and balance transfer
transactions are separate categories of
transactions for purposes of § 706.24 if a
federal credit union applies different annual
percentage rates to each. Furthermore, if, for
example, the federal credit union applies
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different annual percentage rates to different
types of purchase transactions (such as one
rate for purchases of gasoline and a different
rate for all other purchases), each type
constitutes a separate category of transactions
for purposes of § 706.24.
4. Account opening.
i. Multiple accounts with same federal
credit union. When a member has a credit
card account with a federal credit union and
the member opens a new credit card account
with the same federal credit union (or its
affiliate or subsidiary), the opening of the
new account constitutes an ‘‘account
opening’’ for purposes of § 706.24 if, more
than 15/30 days after the new account is
opened, the member has the ability to obtain
additional extensions of credit on each
account. For example, assume that, on
January 1 of year one, a member opens a
credit card account with a federal credit
union. On July 1 of year one, the member
opens a second credit card account with that
federal credit union. On July 15, a $1,000
balance is transferred from the first account
to the second account. The opening of the
second account constitutes the opening of an
account for purposes of § 706.24 so long as,
on July 17/August 1, the member can engage
in transactions using either account. Under
these circumstances, the bank could not
increase an annual percentage rate on the
second account pursuant to § 706.24(b)(3)
until July 1 of year two (which is one year
after the second account was opened).
ii. Replacement or consolidation.
A. Generally. A consumer credit card
account has not been opened for purposes of
§ 227.24 when a consumer credit card
account issued by a bank is replaced or
consolidated with another consumer credit
card account issued by the same bank (or its
affiliate or subsidiary). Circumstances in
which a consumer credit card account has
not been opened for purposes of § 227.24
include when:
(1) A retail credit card is replaced with a
cobranded general purpose card that can be
used at a wider number of merchants;
(2) A credit card account is replaced with
another consumer credit card account
offering different features;
(3) A credit card account is consolidated or
combined with one or more other credit card
accounts into a single credit card account; or
(4) A credit card account acquired through
merger or acquisition is replaced with a
credit card account issued by the acquiring
federal credit union.
B. Limitation. A bank that replaces or
consolidates a consumer credit card account
with another consumer credit card account
issued by the bank (or its affiliate or
subsidiary) may not increase an annual
percentage rate in a manner otherwise
prohibited by § 227.24. For example, assume
that, on January 1 of year one, a consumer
opens a consumer credit card account with
an annual percentage rate for purchases of
15%. On July 1 of year one, the account is
replaced with a consumer credit card account
that offers different features (such as rewards
on purchases). Under these circumstances,
the bank cannot increase the annual
percentage rate for purchases to a rate that is
higher than 15% pursuant to § 227.24(b)(3)
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22:39 May 04, 2009
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until January 1 of year two (which is one year
after the first account was opened).
24(a) General Rule
1. Rates that will apply to each category of
transactions. Section 706.24(a) requires
federal credit unions to disclose, at account
opening, the annual percentage rates that will
apply to each category of transactions on the
account. A federal credit union cannot satisfy
this requirement by disclosing at account
opening only a range of rates or that a rate
will be ‘‘up to’’ a particular amount. The
disclosure requirements in § 706.24(a) do not
apply to annual percentage rates that are
contingent on a particular event or
occurrence or may be applied at the federal
credit union’s discretion (such as penalty
rates) insofar as those rates may be applied
consistent with § 706.24.
2. * * *
i. Assume that, at account opening on
January 1 of year one, a federal credit union
discloses that the annual percentage rate for
purchases is a non-variable rate of 5% and
will apply for six months. The federal credit
union also discloses that, after six months,
the annual percentage rate for purchases will
be a variable rate that is currently 9% and
will be adjusted quarterly by adding a margin
of 3 percentage points to a publicly available
index not under the federal credit union’s
control. Furthermore, the federal credit union
discloses that the annual percentage rate for
cash advances is the same variable rate that
will apply to purchases after six months.
Finally, the federal credit union discloses
that, to the extent consistent with § 706.24
and other applicable law, a non-variable
penalty rate of 15% may apply if a member
makes a late payment. The payment due date
for the account is the twenty-fifth day of the
month and the required minimum periodic
payments are applied to accrued interest and
fees but do not reduce the purchase and cash
advance balances.
*
*
*
*
*
iii. Assume that, at account opening on
January 1 of year one, a federal credit union
discloses that the annual percentage rate for
purchases is a variable rate determined by
adding a margin of 2 percentage points to a
publicly-available index outside of the
federal credit union’s control. The federal
credit union also discloses that, to the extent
consistent with § 706.24 and other applicable
law, a non-variable penalty rate of 15% may
apply if a member makes a late payment. The
due date for the account is the fifteenth of the
month. On May 30 of year two, the account
has a purchase balance of $1,000. On May 31,
the federal credit union provides a notice
pursuant to 12 CFR 226.9(c) informing the
member of a new variable rate that will apply
on July 16 for all purchases made on or after
June 8 (calculated by using the same index
and an increased margin of 8 percentage
points). On June 7, the member makes a $500
purchase. On June 8, the member makes a
$200 purchase. On June 25, the federal credit
union has not received the payment due on
June 15 and provides the member with a
notice pursuant to 12 CFR 226.9(g) stating
that the penalty rate of 15% will apply as of
August 9 to all transactions made on or after
July 3 and that, if the member becomes more
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than 30 days late, the penalty rate will apply
to all balances on the account. On July 4, the
member makes a $300 purchase.
*
*
*
*
*
C. Same facts as paragraph A. above except
the payment due on June 15 of year two is
received on July 20. Section 706.24(b)(4)
permits the federal credit union to apply the
15% penalty rate to all balances on the
account and to future transactions because it
has not received payment within 30 days
after the due date. Because the federal credit
union provided a 12 CFR 226.9(g) notice on
June 25 stating the 15% penalty rate, the
federal credit union may apply the 15%
penalty rate to all balances on the account as
well as any future transactions on August 9
without providing an additional notice
pursuant to 12 CFR 226.9(g).
iv. Assume that, at account opening on
January 1 of year one, the federal credit
union discloses a promotional program under
which interest on purchases made during
January will accrue at a non-variable rate of
10%, but the member will not be obligated
to pay that interest if those purchases are
paid in full by December 31 of year one. On
January 15, the member makes a purchase of
$2,000. No other transactions are made on
the account. The payment due on April 1 is
not received until April 10. Section 706.24
does not permit the federal credit union to
deny the member the opportunity to avoid
interest charges on the $2,000 purchase by
paying that purchase in full on or before
December 31 of year one. If, however, the
$2,000 purchase remains unpaid on January
1 of year two, § 706.24 does not prohibit the
federal credit union from charging the
interest accrued on that purchase during year
one.
24(b) Exceptions
1. Delayed implementation of rate
increase. If § 706.24(b) permits a federal
credit union to apply an increased annual
percentage rate on a date that is not the first
day of a billing cycle, the federal credit union
may delay application of the increased rate
until the first day of the following billing
cycle without relinquishing the ability to
apply that rate. For example, assume that, at
account opening on January 1, a federal
credit union discloses that a non-variable
annual percentage rate of 10% will apply to
purchases for six months and a non-variable
rate of 15% will apply thereafter. The first
day of the billing cycle for the account is the
fifteenth of the month. If the six-month
period expires on July 1, the federal credit
union may delay application of the 15% rate
until July 15 without relinquishing its ability
to apply that rate under § 706.24(b)(1).
24(b)(1) Account Opening Disclosure
Exception
1. Prohibited increases in rate. Section
§ 706.24(b)(1) permits an increase in the
annual percentage rate for a category of
transactions to a rate disclosed at account
opening upon expiration of a period of time
that was also disclosed at account opening.
Section 706.24(b)(1) does not permit
application of an increased annual
percentage rate disclosed at account opening
that is contingent on a particular event or
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occurrence or may be applied at the federal
credit union’s discretion. The following
examples illustrate rate increases that are not
permitted by § 706.24:
2. Application of rate that is lower than
disclosed rate. Section § 706.24(b)(1) permits
an increase in the annual percentage rate for
a category of transactions to a rate disclosed
at account opening upon expiration of a
period of time that was also disclosed at
account opening. Nothing in § 706.24
prohibits a federal credit union from
applying a rate that is lower than a disclosed
rate either during or upon expiration of the
period. However, once the lower rate is
applied to an existing balance, the federal
credit union cannot subsequently increase
the rate on that balance unless it provided
the member with advance notice of the
increase pursuant to 12 CFR 226.9(b) or (c).
This notice must state the period of time
during which the lower rate will apply and
the rate that will apply after expiration of
that period. Furthermore, a federal credit
union that applies a lower rate to
transactions that occurred during the first
year after account opening may not
subsequently increase the rate that applies to
those transactions to a rate that is higher than
the increased rate disclosed at account
opening. The following examples illustrate
the application of the rule:
occurred during the first year after account
opening, the federal credit union cannot
increase the rate that applies to that purchase
to a rate that is higher than the 12% rate
disclosed at account opening.
B. Same facts as above except that the
required minimum periodic payment due on
November 10 of year one is not received until
November 15. Section 706.24(b)(1) does not
permit the federal credit union to increase
any annual percentage rate on the account at
this time. The federal credit union may,
however, apply the 15% penalty rate to new
transactions beginning on January 1 of year
two pursuant to § 706.24(b)(3) by providing
a 12 CFR 226.9(g) notice informing the
member of this increase no later than
November 16 of year one. On January 1 of
year two, § 706.24(b)(1) permits the federal
credit union to begin accruing interest on the
$1,400 purchase balance at 12% (as disclosed
at account opening). If the member makes the
$150 purchase on January 15 of year two,
§ 706.24(b)(3) would permit the federal credit
union to apply the 15% rate to that purchase.
On April 1 of year two, the 7% rate that
applies to the $300 purchase expires.
Because this purchase occurred during the
first year after account opening, the federal
credit union cannot increase the rate that
applies to that purchase to a rate that is
higher than the 12% rate disclosed at account
opening.
*
24(b)(2)
*
*
*
*
*
*
*
*
*
ii. Assume that a federal credit union
discloses at account opening on January 1 of
year one that a non-variable annual
percentage rate of 10% will apply to
purchases for one year, after which that rate
will increase to a non-variable rate of 12%.
The federal credit union also discloses that,
to the extent consistent with § 706.24 and
other applicable law, a non-variable penalty
rate of 15% may apply if the member’s
required minimum periodic payment is
received after the payment due date, which
is the tenth of the month. The required
minimum periodic payments are applied to
accrued interest and fees but do not reduce
the purchase balance.
A. On September 30 of year one, the
account has a purchase balance of $1,400 at
the 10% rate. On October 1, the federal credit
union provides a notice pursuant to 12 CFR
226.9(c) informing the member that the rate
for new purchases will decrease to a nonvariable rate of 7% for six months (from
October 1 through March 31 of year two) and
that, beginning on April 1 of year two, the
rate for purchases will increase to a nonvariable rate of 13%. The federal credit union
does not apply the 7% rate to the $1,400
purchase balance. On October 15 of year one,
the member makes a $300 purchase at the 7%
rate. On January 1 of year two, the federal
credit union may begin accruing interest on
the $1,400 purchase balance at 12% (as
disclosed at account opening). On January 15
of year two, the member makes a $150
purchase at the 7% rate. On April 1 of year
two, the 7% rate that applies to the $300
purchase and the $150 purchase expires. The
federal credit union may begin accruing
interest on the $150 purchase at 13% (as
disclosed in the 12 CFR 226.9(c) notice).
Because, however, the $300 purchase
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22:39 May 04, 2009
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*
*
Variable Rate Exception
*
*
*
5. Changing a variable rate to a nonvariable rate. * * *
*
*
24(b)(3)
*
*
*
*
*
Advance Notice Exception
*
*
*
2. Transactions that occurred prior to
provision of notice or within seven days after
provision of notice. Section 706.24(b)(3)
generally permits a federal credit union to
apply an increased rate to transactions that
occur after provision of a 12 CFR 226.9(b)
notice or more than seven days after
provision of a 12 CFR 226.9(c) or (g) notice.
If a rate increase is disclosed pursuant to
both 12 CFR 226.9(b) and 12 CFR 226.9(c),
that rate may only be applied to transactions
that occur more than seven days after
provision of the 12 CFR 226.9(c) notice.
Section 706.24(b)(3) does not permit a federal
credit union to reach back to days before the
effective date of the rate increase under 12
CFR 226.9(c) or (g) when calculating interest
charges. See comment 24(b)(3)–3. Whether a
transaction occurred prior to provision of a
notice or within seven days after provision of
a notice is determined by the date of the
transaction. In some cases, however, a
merchant may place a ‘‘hold’’ on the
available credit on an account for an
estimated transaction amount when the
actual transaction amount will not be known
until a later date. In these circumstances, the
date of the transaction for purposes of
§ 706.24(b)(3) is the date on which the
merchant determines the actual transaction
amount. For example, assume that, when a
member uses a credit card account to check
into a hotel on July 1, the hotel obtains
authorization for a $750 hold on the account
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to ensure there is adequate available credit to
cover the anticipated cost of the stay. When
the member checks out on July 4, the actual
cost of the stay is $850 because of additional
incidental costs, and the hotel charges this
amount to the account. For purposes of
§ 706.24(b)(3), the transaction occurred on
July 4.
3. Examples.
i. Assume that a consumer credit card
account is opened on January 1 of year one.
On March 14 of year two, the account has a
purchase balance of $2,000 at a non-variable
annual percentage rate of 5%. On March 15,
the federal credit union provides a notice
pursuant to 12 CFR 226.9(c) informing a
member that the rate for new purchases will
increase to a non-variable rate of 8% on May
1. The notice further states that the 8% rate
will apply for six months (until November 1)
and states that thereafter the federal credit
union will apply a variable rate that is
currently 9% and is determined by adding a
margin of 5 percentage points to a publiclyavailable index that is not under the federal
credit union’s control. The seventh day after
provision of the notice is March 22 and, on
that date, the member makes a $200
purchase. On March 24, the member makes
a $1,000 purchase. On May 1, § 706.24(b)(3)
permits the federal credit union to begin
accruing interest at 8% on the $1,000
purchase made on March 24. The federal
credit union is not permitted to apply the 8%
rate to the $2,200 purchase balance as of
March 22. After six months (November 2),
the federal credit union may begin accruing
interest on any remaining portion of the
$1,000 purchase at the previously-disclosed
variable rate determined using the 3-point
margin.
ii. Same facts as above except that on
September 17 of year two (which is 45 days
before expiration of the 8% non-variable
rate), the federal credit union provides a
notice pursuant to 12 CFR 226.9(c) informing
the member that, on November 2, a new
variable rate will apply to new purchases and
any remaining portion of the $1,000 balance
(calculated by using the same index and a
reduced margin of 3 percentage points). The
notice further states that, on May 1 of year
three, the margin will increase to the margin
disclosed in the March 15 notice (6
percentage points). On May 1 of year three,
§ 706.24(b)(3) permits the federal credit
union to increase the margin used to
determine the variable rate that applies to
new purchases to 5 percentage points and to
apply that rate to any remaining portion of
the $1,000 purchase as well as to new
purchases. The federal credit union is not
permitted to apply this rate to any remaining
portion of the $2,200 purchase balance as of
March 22.
4. Application of a lower rate. Nothing in
§ 706.24 prohibits a federal credit union from
lowering the annual percentage rate that
applies to an existing balance or to new
transactions. However, once the lower rate is
applied to an existing balance, the federal
credit union cannot subsequently increase
the rate on that balance unless it provided a
member with advance notice of the increase
pursuant to 12 CFR 226.9(b) or (c). This
notice must state the period of time during
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which the lower rate will apply and the rate
that will apply after expiration of that period.
Furthermore, a federal credit union that
applies a decreased rate to transactions that
occurred prior to provision of the notice—or,
in the case of a 12 CFR 226.9(c) or (g) notice,
transactions that occurred within seven days
after provision of the notice—may not
subsequently increase the rate that applies to
those transactions to a rate that is higher than
the rate that applied prior to the decrease.
The following examples illustrate the
application of the rule:
i. Assume that a federal credit union
discloses at account opening on January 1 of
year one that a non-variable annual
percentage rate of 7% will apply to purchases
for one year, after which that rate will
increase to a non-variable rate of 9%. The
federal credit union also discloses that, to the
extent consistent with § 706.24 and other
applicable law, a non-variable penalty rate of
15% may apply if the member’s required
minimum periodic payment is received after
the payment due date, which is the tenth of
the month. The required minimum periodic
payments are applied to accrued interest and
fees but do not reduce the purchase balance.
On June 30 of year two, the account has a
purchase balance of $1,000 at the 9% rate.
On July 1, the federal credit union provides
a notice pursuant to 12 CFR 226.9(c)
informing the consumer that the rate for new
purchases will decrease to a non-variable rate
of 5% for six months (from July 1 through
December 31 of year two) and that, beginning
on January 1 of year three, the rate for
purchases will increase to a non-variable rate
of 10%. On July 8 of year two, the member
makes a $200 purchase. On July 9, the
member makes a $100 purchase. On January
1 of year three, § 706.24(b)(3) permits the
federal credit union to begin accruing interest
on the $100 purchase at 10%. The federal
credit union may not apply the 10% rate to
the $200 purchase because that transaction
occurred within seven days after provision of
the 12 CFR 226.9(c) notice. If the federal
credit union applied the 5% rate to the
$1,000 purchase balance and the $200
purchase, the federal credit union may not
increase the rate that applies to those
amounts to a rate that is higher than 9% on
January 1 of year three.
ii. Same facts as above except that the
required minimum periodic payment due on
September 10 of year two is not received
until September 15 of year two. On
September 15 of year two, the federal credit
union provides a notice pursuant to 12 CFR
226.9(g) informing the member that the rate
for new purchases will increase to the 15%
penalty rate on October 31. On October 31,
§ 706.23(b)(3) permits the federal credit
union to begin accruing interest at 15% on
any purchase made on or after September 23.
The federal credit union may not, however,
apply the 15% rate to the $1,300 in
purchases. Instead, the federal credit union
must continue to apply the 5% rate to the
$100 purchase until at least January 1 of year
three when § 706.24(b)(3) permits the federal
credit union to begin accruing interest on
that purchase at 10%. Similarly, if the federal
credit union applied the 5% rate to the
$1,000 purchase balance and the $200
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22:39 May 04, 2009
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purchase, the federal credit union may begin
accruing interest on those amounts at 9% on
January 1 of year three.
iii. Assume that a federal credit union
discloses at account opening on January 1 of
year one that the rate that applies to
purchases is a variable annual percentage
rate that is currently 7% and will be adjusted
quarterly by adding a margin of 3 percentage
points to a publicly available index not under
the federal credit union’s control. The federal
credit union also discloses that, to the extent
consistent with § 706.24 and other applicable
law, a non-variable penalty rate of 15% may
apply if the member’s required minimum
periodic payment is received after the
payment due date, which is the first of the
month. On July 30 of year two, the member
uses the account for a $1,000 purchase in
response to a promotional offer. Under the
terms of this offer, interest on purchases
made during the months of July through
September will accrue at the variable rate for
purchases but the member will not be
obligated to pay that interest if all purchases
made during that three-month period are
paid in full by December 31 of year two. The
payment due on September 1 of year two is
not received until September 6. Section
706.24 does not permit the federal credit
union to deny the member the opportunity to
avoid interest charges on the $1,000 purchase
by paying that purchase in full on or before
December 31 of year two. The federal credit
union may, however, provide a notice
pursuant to 12 CFR 226.9(g) on September 2
of year two informing the member that the
promotional offer does not apply to
purchases made on or after September 10 and
that the rate for such purchases will increase
to the 15% penalty rate on October 18. On
December 31 of year two, the $1,000
purchase has been paid in full. Under these
circumstances, the federal credit union may
not charge any interest accrued on the $1,000
purchase.
iv. Assume that a federal credit union
discloses at account opening on January 1 of
year one that the rate that applies to cash
advances is a variable annual percentage rate
that is currently 9% and will be adjusted
quarterly by adding a margin of 3 percentage
points to a publicly available index not under
the federal credit union’s control. On July 1
of year two, the federal credit union provides
checks that access the account and, pursuant
to 12 CFR 226.9(b)(3)(A), discloses that a
promotional rate of 5% will apply to credit
extended by use of the checks until January
1 of year three, after which the cash advance
rate determined using the 3-point margin will
apply. On July 15 of year two, the member
uses one of the checks to pay for a $500
transaction. On January 1 of year three,
§ 706.24(b)(3) permits the federal credit
union to apply the cash advance rate
determined using the 3-point margin to the
$500 transaction.
24(b)(5) Workout and Temporary Hardship
Arrangement Exception
1. Scope of exception. Nothing in
§ 706.24(b)(5) permits a federal credit union
to alter the requirements of § 706.24 pursuant
to a workout or temporary hardship
arrangement between a member and the
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federal credit union. For example, a federal
credit union cannot increase an annual
percentage rate pursuant to a workout or
temporary hardship arrangement unless
otherwise permitted by § 706.24. In addition,
a federal credit union cannot require the
member to make payments with respect to a
protected balance that exceeds the payments
permitted under § 706.24(c).
2. Variable rates. If the annual percentage
rate that applied to a category of transactions
prior to commencement of the workout or
temporary hardship arrangement varied with
an index consistent with § 706.24(b)(2), the
rate applied to that category of transactions
following an increase pursuant to
§ 706.24(b)(5) must be determined using the
same formula (index and margin).
3. Examples.
i. Assume that, consistent with
§ 706.24(b)(4), the margin used to determine
a variable annual percentage rate that applies
to a $5,000 balance is increased from 3
percentage points to 5 percentage points.
Assume also that the federal credit union and
the member subsequently agree to a workout
arrangement that reduces the margin back to
3 points on the condition that the member
pay a specified amount by the payment due
date each month. If the member does not pay
the agreed-upon amount by the payment due
date, the federal credit union may increase
the margin for the variable rate that applies
to the $5,000 balance up to 5 percentage
points. 12 CFR 226.9 does not require
advance notice of this type of increase.
ii. Assume that a member fails to make four
consecutive minimum payments totaling
$480 on a consumer credit card account with
a balance of $6,000 and that, consistent with
§ 706.24(b)(4), the annual percentage rate that
applies to that balance is increased from a
non-variable rate of 5% to a non-variable
penalty rate of 15%. Assume also that the
federal credit union and the member
subsequently agree to a temporary hardship
arrangement that reduces all rates on the
account to 0% on the condition that the
member pay an amount by the payment due
date each month that is sufficient to cure the
$480 delinquency within six months. If the
member pays the agreed-upon amount by the
payment due date during the six-month
period and cures the delinquency, the federal
credit union may increase the rate that
applies to any remaining portion of the
$6,000 balance to 5% or any other rate up to
the 15% penalty rate.
24(c)
*
Treatment of Protected Balances
*
24(c)(1)
*
*
*
*
*
Repayment
*
*
*
Paragraph 24(c)(1)(i)
*
*
*
*
*
2. Amortization when applicable rate is
variable. * * *
*
*
*
*
*
24(c)(2) Fees and Charges
1. Fee or charge based solely on the
protected balance. A federal credit union is
prohibited from assessing a fee or charge
based solely on balances to which § 706.24(c)
applies. For example, a federal credit union
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is prohibited from assessing a monthly
maintenance fee that would not be charged
if the account did not have a protected
balance. A federal credit union is not,
however, prohibited from continuing to
assess a periodic fee that was assessed before
the account had a protected balance.
Similarly, a federal credit union is not
prohibited from assessing fees such as late
payment fees or fees for exceeding the credit
limit even if such fees are based in part on
the protected balance or if the only balance
on the account is a protected balance.
§ 706.25—Unfair Balance Computation
Method
25(a)
*
3. Charging accrued interest at expiration
of certain promotional programs. When a
federal credit union offers a promotional
program under which a member will not be
obligated to pay interest that accrues on a
balance if that balance is paid in full prior
to a specified date or expiration of a specified
period of time, § 706.25 does not prohibit the
federal credit union from charging that
accrued interest to the account if the balance
is not paid in full prior to the specified date
(consistent with applicable law and
regulatory guidance).
*
*
*
*
*
General Rule
*
*
VerDate Nov<24>2008
*
Jennifer J. Johnson,
Secretary of the Board.
Dated: April 17, 2009.
By the Office of Thrift Supervision.
John E. Bowman,
Acting Director.
By the National Credit Union
Administration Board, on April 24, 2009.
Mary F. Rupp,
Secretary of the Board.
[FR Doc. E9–9861 Filed 5–4–09; 8:45 am]
BILLING CODE 6210–01–P, 6720–01–P, 7535–01–P
*
22:39 May 04, 2009
By order of the Board of Governors of the
Federal Reserve System, April 24, 2009.
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E:\FR\FM\05MYP3.SGM
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Agencies
[Federal Register Volume 74, Number 85 (Tuesday, May 5, 2009)]
[Proposed Rules]
[Pages 20804-20832]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-9861]
[[Page 20803]]
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Part III
Federal Reserve System
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Department of the Treasury
Office of Thrift Supervision
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National Credit Union Administration
12 CFR Part 227, 535, and 706
Unfair or Deceptive Acts or Practices; Clarifications; Proposed Rule
Federal Register / Vol. 74, No. 85 / Tuesday, May 5, 2009 / Proposed
Rules
[[Page 20804]]
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FEDERAL RESERVE SYSTEM
12 CFR Part 227
[Regulation AA; Docket No. R-1314]
DEPARTMENT OF THE TREASURY
Office of Thrift Supervision
12 CFR Part 535
[Docket ID OTS-2009-0006]
RIN 1550-AC17
NATIONAL CREDIT UNION ADMINISTRATION
12 CFR Part 706
RIN 3133-AD62
Unfair or Deceptive Acts or Practices; Clarifications
AGENCIES: Board of Governors of the Federal Reserve System (Board);
Office of Thrift Supervision, Treasury (OTS); and National Credit Union
Administration (NCUA).
ACTION: Proposed rule; request for public comment.
-----------------------------------------------------------------------
SUMMARY: In December 2008, the Board, OTS, and NCUA (collectively, the
Agencies) exercised their authority under the Federal Trade Commission
Act to issue a final rule prohibiting institutions from engaging in
specific acts or practices in connection with consumer credit card
accounts. The Agencies understand that clarification is needed
regarding certain aspects of the final rule. Accordingly, in order to
facilitate compliance, the Agencies propose to amend specific portions
of the regulations and official staff commentary.
DATES: Comments must be received on or before June 4, 2009.
ADDRESSES: Because paper mail in the Washington DC area and at the
Agencies is subject to delay, we encourage commenters to submit
comments by e-mail, if possible. We also encourage commenters to use
the title ``Unfair or Deceptive Acts or Practices'' to facilitate our
organization and distribution of the comments. Comments submitted to
one or more of the Agencies will be made available to all of the
Agencies. Interested parties are invited to submit comments as follows:
Board: You may submit comments, identified by Docket No. R-1314, by
any of the following methods:
Agency Web site: https://www.federalreserve.gov. Follow the
instructions for submitting comments at https://www.federalreserve.gov/generalinfo/foia/ProposedRegs.cfm.
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: regs.comments@federalreserve.gov. Include the
docket number in the subject line of the message.
Facsimile: (202) 452-3819 or (202) 452-3102.
Mail: Jennifer J. Johnson, Secretary, Board of Governors
of the Federal Reserve System, 20th Street and Constitution Avenue,
NW., Washington, DC 20551.
All public comments are available from the Board's Web site at
https://www.federalreserve.gov/generalinfo/foia/ProposedRegs.cfm as
submitted, unless modified for technical reasons. Accordingly, your
comments will not be edited to remove any identifying or contact
information. Public comments may also be viewed electronically or in
paper form in Room MP-500 of the Board's Martin Building (20th and C
Streets, NW.), between 9 a.m. and 5 p.m. on weekdays.
OTS: You may submit comments, identified by OTS-2009-0006, by any
of the following methods:
Federal eRulemaking Portal-``Regulations.gov'': Go to
https://www.regulations.gov, under the ``more Search Options'' tab click
next to the ``Advanced Docket Search'' option where indicated, select
``Office of Thrift Supervision'' from the agency drop-down menu, then
click ``Submit.'' In the ``Docket ID'' column, select ``OTS-2009-0006''
to submit or view public comments and to view supporting and related
materials for this proposed rulemaking. The ``How to Use This Site''
link on the Regulations.gov home page provides information on using
Regulations.gov, including instructions for submitting or viewing
public comments, viewing other supporting and related materials, and
viewing the docket after the close of the comment period.
Mail: Regulation Comments, Chief Counsel's Office, Office
of Thrift Supervision, 1700 G Street, NW., Washington, DC 20552,
Attention: OTS-2009-0006.
Facsimile: (202) 906-6518.
Hand Delivery/Courier: Guard's Desk, East Lobby Entrance,
1700 G Street, NW., from 9 a.m. to 4 p.m. on business days, Attention:
Regulation Comments, Chief Counsel's Office, Attention: OTS-2009-0006.
Instructions: All submissions received must include the
agency name and docket number for this rulemaking. All comments
received will be entered into the docket and posted on Regulations.gov
without change, including any personal information provided. Comments,
including attachments and other supporting materials received are part
of the public record and subject to public disclosure. Do not enclose
any information in your comment or supporting materials that you
consider confidential or inappropriate for public disclosure.
Viewing Comments Electronically: Go to https://www.regulations.gov, select ``Office of Thrift Supervision'' from the
agency drop-down menu, then click ``Submit.'' Select Docket ID ``OTS-
2009-0006'' to view public comments for this notice of proposed
rulemaking.
Viewing Comments On-Site: You may inspect comments at the
Public Reading Room, 1700 G Street, NW., by appointment. To make an
appointment for access, call (202) 906-5922, send an e-mail to
public.info@ots.treas.gov">public.info@ots.treas.gov, or send a facsimile transmission to (202)
906-6518. (Prior notice identifying the materials you will be
requesting will assist us in serving you.) We schedule appointments on
business days between 10 a.m. and 4 p.m. In most cases, appointments
will be available the next business day following the date we receive a
request.
NCUA: You may submit comments, identified by number RIN 3133-AD62,
by any of the following methods:
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
NCUA Web site: https://www.ncua.gov/news/proposed_regs/proposed_regs.html. Follow the instructions for submitting comments.
E-mail: Address to regcomments@ncua.gov. Include ``[Your
name] Comments on Proposed Rule Part 706'' in the e-mail subject line.
Facsimile: (703) 518-6319. Use the subject line described
above for e-mail.
Mail: Address to Mary Rupp, Secretary of the Board,
National Credit Union Administration, 1775 Duke Street, Alexandria, VA
22314-3428.
Hand Delivery/Courier: Same as mail address.
Public Inspection: All public comments are available on
the agency's Web site at https://www.ncua.gov/RegulationsOpinionsLaws/comments as submitted, except as may not be possible for technical
reasons. Public comments will not be edited to remove any identifying
or contact information. Paper copies of comments may be inspected in
NCUA's law library at 1775 Duke Street, Alexandria, Virginia 22314, by
appointment, weekdays between 9 a.m. and 3 p.m. To make an appointment,
call (703) 518-6540 or send an e-mail to OGCMail@ncua.gov.
FOR FURTHER INFORMATION CONTACT:
[[Page 20805]]
Board: Benjamin K. Olson, Attorney, or Ky Tran-Trong, Counsel,
Division of Consumer and Community Affairs, at (202) 452-2412 or (202)
452-3667, Board of Governors of the Federal Reserve System, 20th and C
Streets, NW., Washington, DC 20551. For users of Telecommunications
Device for the Deaf (TDD) only, contact (202) 263-4869.
OTS: April Breslaw, Director, Consumer Regulations, (202) 906-6989;
Suzanne McQueen, Consumer Regulations Analyst, Compliance and Consumer
Protection Division, (202) 906-6459; or Richard Bennett, Senior
Compliance Counsel, Regulations and Legislation Division, (202) 906-
7409, at Office of Thrift Supervision, 1700 G Street, NW., Washington,
DC 20552.
NCUA: Matthew J. Biliouris, Program Officer, Office of Examination
and Insurance, (703) 518-6360; or Moisette I. Green, Staff Attorney,
Office of General Counsel, (703) 518-6540, National Credit Union
Administration, 1775 Duke Street, Alexandria, VA 22314-3428.
SUPPLEMENTARY INFORMATION:
I. Background
In December 2008, the Federal Reserve Board (Board), the Office of
Thrift Supervision (OTS), and the National Credit Union Administration
(NCUA) (collectively, the Agencies) adopted a final rule under the
Federal Trade Commission Act (FTC Act) to protect consumers from unfair
acts or practices with respect to consumer credit card accounts. This
rule was published in the Federal Register on January 29, 2009. See 74
FR 5498 (January 2009 Rule). On that same date, the Board published a
final rule amending the provisions regarding open-end credit (not home
secured) in Regulation Z, which implements the Truth in Lending Act
(TILA). See 74 FR 5244 (January 2009 Regulation Z Rule). The effective
date for both rules is July 1, 2010. See 74 FR 5548; 74 FR 5388-5390.
Since publication of the two rules, the Agencies have become aware
that clarification is needed to resolve confusion regarding how
institutions will comply with particular aspects of those rules.
Accordingly, in order to provide guidance and facilitate compliance
with the January 2009 Rule by the effective date, the Agencies propose
to amend portions of the rule and the accompanying staff commentary.
These proposed amendments are discussed in detail in section III of
this SUPPLEMENTARY INFORMATION. Similarly, elsewhere in today's Federal
Register, the Board has proposed to amend certain aspects of the
January 2009 Regulation Z Rule.
Although comment is requested on the proposed amendments, the
Agencies emphasize that the purpose of these rulemakings is to clarify
and facilitate compliance with the final rule, not to reconsider the
need for--or the extent of--the protections that the rule affords
consumers. Thus, commenters are encouraged to limit their submissions
accordingly.
In addition, because the Agencies do not intend to extend the
effective date for the January 2009 Rule, any amendments must be
adopted in final form with sufficient time for institutions to
implement the amended rule on or prior to July 1, 2010. The Agencies
emphasize that, because this rulemaking focuses on clarifications to
discrete aspects of the January 2009 Rule, institutions should continue
their efforts to come into compliance with that rule as soon as
practicable and, in any event, prior to July 1, 2010. In order to
ensure that final clarifications can be provided as soon as possible,
the Agencies are requiring that comments on this proposal be submitted
within 30 days from publication in the Federal Register.\1\
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\1\ Generally, NCUA gives the public 60 days to comment on
proposed rules; however, a shorter comment period is appropriate in
this instance to ensure compliance with the January 2009 Rule. See
IRPS 87-2, 52 FR 35231 (Sept. 18, 1987).
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II. Statutory Authority
Section 18(f)(1) of the FTC Act provides that the Board (with
respect to banks), OTS (with respect to savings associations), and the
NCUA (with respect to federal credit unions) are responsible for
prescribing ``regulations defining with specificity * * * unfair or
deceptive acts or practices, and containing requirements prescribed for
the purpose of preventing such acts or practices.'' 15 U.S.C.
57a(f)(1). In the SUPPLEMENTARY INFORMATION for the January 2009 Rule,
the Agencies set forth the standards codified by Congress or adopted by
the Federal Trade Commission for determining whether an act or practice
is unfair or deceptive and applied those standards to the practices
prohibited by the final rule. See 74 FR 5501 et seq. In addition, the
OTS relied on its authority under the Home Owners' Loan Act (HOLA) as a
secondary basis for its final rule. See, e.g., 74 FR 5505-5506. For
purposes of this rulemaking, the Agencies continue to rely on this
legal authority and analysis.
III. Section-by-Section Analysis
The final rules adopted by the Board, OTS, and NCUA under the FTC
Act are located in, respectively, parts 227, 535, and 706 of title 12
of the Code of Federal Regulations. For purposes of the discussion in
this SUPPLEMENTARY INFORMATION, the Agencies use the shared numerical
suffix for each provision. For example, Sec. --.21 refers to the
Board's 12 CFR 227.21, the OTS's 12 CFR 535.21, and the NCUA's 12 CFR
706.21.
Section --.21--Definitions
Subpart C to the Agencies' rules contains the provisions addressing
consumer credit card accounts. Section --.21 defines certain terms used
in Subpart C.
Section --.21(a) Annual Percentage Rate
Section --.21(a) defines ``annual percentage rate'' as the product
of multiplying each periodic rate for a balance or transaction on a
consumer credit card account by the number of periods in a year. In the
text of the regulations and in the commentary, the Agencies sometimes
use the term ``rate'' in place of ``annual percentage rate'' to
conserve space and avoid repetition. To avoid possible confusion, the
Agencies propose to add a new comment 21(a)-1, clarifying that, for
purposes of Subpart C, ``rate'' has the same meaning as ``annual
percentage rate'' unless otherwise specified. Furthermore, for clarity
and consistency, the Agencies propose to substitute ``rate'' for
``annual percentage rate'' in the titles to certain comments. See
comments 23-3, 23-6, 24(b)(2)-5, 24(b)(5)-2, 24(c)(1)(i)-2.
Section --.21(c) Consumer Credit Card Account
The provisions of Subpart C apply to ``consumer credit card
accounts,'' which are defined in Sec. --.21(c) as accounts provided to
a consumer primarily for personal, family, or household purposes under
an open-end credit plan that is accessed by a credit or charge card.
Based on questions received following issuance of the January 2009
Rule, the Agencies understand that clarification is needed regarding
whether an outstanding balance on a consumer credit card account
remains subject to Subpart C when the account is closed, when the
account is acquired by another institution, and when the balance is
transferred to another credit account. In particular, concerns have
been raised that permitting institutions to apply an increased rate to
an outstanding balance in these circumstances could lead to
[[Page 20806]]
circumvention of the general prohibition in Sec. --.24 on such
increases.
To address these concerns, the Agencies propose to add comments
21(c)-1 through 3, which would clarify that, as a general matter, the
protections in Subpart C continue to apply to an outstanding balance
following the closure or acquisition of the account or the transfer of
the balance to another credit account issued by the same institution
(or its affiliate or subsidiary). Accordingly, in these circumstances,
an institution must, for example, continue to provide consumers a
reasonable amount of time to make payment on such balances pursuant to
Sec. --.22; allocate payments in excess of the required minimum
periodic payment among such balances consistent with Sec. --.23; and
increase the annual percentage rates that apply to such balances only
to the extent permitted by Sec. --.24.
Because the protections in Subpart C cannot be waived or forfeited,
the proposed comments do not distinguish between closures or transfers
initiated by the institution and closures or transfers initiated by the
consumer. In the January 2009 Rule, the Agencies determined that,
because many of the prohibited practices cannot be effectively
disclosed, consumers are unable to reasonably avoid the harm caused by
those practices. Thus, as discussed below, allowing institutions to
engage in the prohibited practices by obtaining the consumer's
agreement could undercut the purpose of the rule.
Although there may be circumstances in which individual consumers
could make informed choices about the benefits and costs of waiving the
protections in Subpart C, an exception for those circumstances would
create a significant loophole that could be used to deny the
protections to other consumers. For example, if an institution offered
to transfer its cardholder's outstanding balance to a credit product
that would reduce the rate on the balance for a period of time in
exchange for the cardholder accepting a higher rate after that period,
the cardholder would have to determine whether the savings created by
the temporary reduction would offset the cost of the subsequent
increase, which would depend on the amount of the balance, the amount
and length of the reduction, the amount of the increase, and the length
of time it would take the consumer to pay off the balance at the
increased rate. Based on extensive consumer testing conducted during
the preparation of the January 2009 Rule (and the Board's January 2009
Regulation Z Rule), the Agencies believe that it would be very
difficult to ensure that institutions disclose this information in a
manner that will enable most consumers to make informed decisions about
whether to accept the increase in rate. Although some approaches to
disclosure may be effective, others may not and it would be impossible
to distinguish among such approaches in a way that would provide clear
guidance for institutions. Furthermore, consumers might be presented
with choices that are not meaningful (such as a choice between
accepting a higher rate on an outstanding balance or losing credit
privileges on the account). Thus, the proposed commentary to Sec.
--.21(c) would clarify that, as a general matter, the protections in
Subpart C do not depend on whether the consumer agrees to the closure
of an account or the transfer of a balance.
Accordingly, proposed comment 21(c)-1 states that, if a consumer
credit card account with an outstanding balance is closed by the
consumer or the institution, the account continues to be the same
consumer credit card account for purposes of Subpart C with respect to
that balance. Thus, in these circumstances, the institution could not
increase the rate that applies to the outstanding balance (except to
the extent permitted by Sec. --.24).
Proposed comment 21(c)-2 addresses circumstances in which an
institution acquires a consumer credit card account with an outstanding
balance by, for example, merging with or acquiring another institution
or by purchasing another institution's credit card portfolio. In some
cases, the acquiring institution may elect to close the acquired
account and replace it with its own credit card account. See 12 CFR
226.12 comment 12(a)(2)-3. The acquisition of an account does not
involve any choice on the part of consumers, and the Agencies believe
that consumers whose accounts are acquired should receive the same
level of protection after acquisition as they did beforehand.
Accordingly, the proposed comment states that an institution that
acquires a consumer credit card account remains subject to the
provisions of Subpart C with respect to any outstanding balances on the
account. For example, the institution would generally be prohibited
from increasing the annual percentage rate on an outstanding purchase
balance to the rate that the institution applies to purchases on its
accounts.\2\
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\2\ Thus, the acquiring institution would not be permitted to
substitute a new index for the index applicable to an acquired
variable rate balance if the change could result in an increase in
the applicable annual percentage rate. See comment 24(b)(2)-1. An
institution that does not utilize the index used to determine the
variable rate for an acquired balance may, however, convert that
rate to an equal or lower non-variable rate, subject to the notice
requirements of 12 CFR 226.9(c). See comment 24(b)(2)-5.
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Finally, proposed comment 21(c)-3 addresses balance transfers
between accounts issued by the same institution (or its affiliate or
subsidiary) and balance transfers between accounts issued by different
institutions. Balances may be transferred from one consumer credit card
account issued by an institution to another consumer credit card
account issued by the same institution when, for example, the
consumer's account is converted from a retail credit card that may only
be used at a single retailer or affiliated group of retailers to a co-
branded general purpose credit card which may be used at a wider number
of merchants. Because of the concerns discussed above regarding
circumvention and informed consumer choice and for consistency with the
issuance rules regarding card renewals or substitutions for accepted
credit cards under Regulation Z, 12 CFR 226.12(a)(2), the Agencies
believe--and proposed comment 21(c)-3 states--that these transfers
should be treated as a continuation of the existing account
relationship rather than the creation of a new account relationship.
See 12 CFR 226.12 comment 12(a)(2)-2. Similarly, proposed comment
21(c)-3 would apply to circumstances where a balance is transferred to
a line of credit accessed solely by an account number or another type
of credit account issued by the same institution or its affiliate or
subsidiary (except for an open-end credit plan secured by the
consumer's dwelling).\3\ Accordingly, under these circumstances, an
institution could not, for example, apply an increased rate to an
existing balance in a manner prohibited by Sec. --.24.
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\3\ Proposed comment 21(c)-3 clarifies that Subpart C would not
apply to balances transferred from a consumer credit card account
issued by an institution to an open-end credit plan secured by the
consumer's dwelling issued by the same institution (or its affiliate
or subsidiary) because these plans provide protections that are
similar to--and, in some cases, more stringent than--the protections
in Subpart C. For example, a creditor may not change the annual
percentage rate on a home-equity plan unless the change is based on
an index that is not under the creditor's control and is available
to the general public. See 12 CFR 226.5a(f)(1).
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In contrast, proposed comment 21(c)-3 also states that, when a
consumer chooses to transfer a balance to a consumer credit card
account issued by a different institution, Subpart C does not prohibit
the institution to which the balance is transferred from applying its
[[Page 20807]]
account terms to that balance, provided those terms comply with Subpart
C. For example, if a consumer credit card account issued by institution
A has a $1,000 purchase balance at an annual percentage rate of 15% and
the consumer transfers that balance to a consumer credit card account
with a purchase rate of 17% issued by institution B, institution B may
apply the 17% rate to the $1,000 balance. However, institution B may
not subsequently increase the rate that applies to that balance unless
permitted by one of the exceptions in Sec. --.24(b).
Although balance transfers from one institution to another raise
some of the same concerns as balance transfers involving the same
institution, the Agencies believe that transfers between institutions
are not contrary to Subpart C because the institution to which the
balance is transferred is not increasing the cost of credit it
previously extended to the consumer. For example, assume that
institution A has extended a consumer $1,000 of credit at a rate of
15%. Because Sec. --.24 generally prohibits institution A from
increasing the rate that applies to that balance, it would be
inconsistent with Sec. --.24 to allow institution A to reprice that
balance simply by transferring it to another account. In contrast, in
order for the $1,000 balance to be transferred to institution B,
institution B must provide the consumer with a new $1,000 extension of
credit in an arms-length transaction and should be permitted to price
that new extension consistent with its evaluation of prevailing market
rates, the risk presented by the consumer, and other factors. Thus, the
transfer from institution A to institution B does not appear to raise
concerns about circumvention of Sec. --.24 because institution B is
not increasing the cost of credit it previously extended.
The Agencies understand that drawing this distinction between
balance transfers involving the same institution and balance transfers
involving different institutions may limit an institution's ability to
offer its existing cardholders the same terms that it would offer
another institution's cardholders. Currently, however, the Agencies
understand that institutions generally do not make promotional balance
transfer offers available to their existing cardholders for balances
held by the institution because it is not cost-effective to do so.
Furthermore, although many institutions do offer existing cardholders
the opportunity to upgrade to accounts offering different terms or
features (such as upgrading to an account that offers a particular type
of rewards), the Agencies understand that these offers generally are
not conditioned on a balance transfer, which indicates that it may be
cost-effective for institutions to make these offers without repricing
an outstanding balance. Nevertheless, the Agencies solicit comment on
the extent to which proposed comment 21(c)-3 would affect institutions'
ability to make offers to existing cardholders.
Section --.22--Unfair Acts or Practices Regarding Time To Make Payment
Section --.22(a) provides that an institution must not treat a
payment on a consumer credit card account as late for any purpose
unless the consumer has been provided a reasonable amount of time to
make the payment. Section --.22(b)(1) states that an institution must
be able to demonstrate that it has complied with this requirement, and
Sec. --.22(b)(2) provides a safe harbor for institutions that have
adopted reasonable procedures designed to ensure that periodic
statements specifying the payment due date are mailed or delivered to
consumers at least 21 days before the payment due date.
Comment 22(b)-3 offers an example of an alternative method of
complying with Sec. --.22(a). In this example, an institution that
only provides periodic statements electronically and only accepts
payments electronically for a particular type of consumer credit card
account could comply with Sec. --.22(a) even if it does not provide
periodic statements 21 days before the payment due date. The Agencies
understand that, although the example states that this type of account
must also comply with ``applicable law and regulatory guidance,'' an
explicit reference to the consumer notice and consent procedures of the
Electronic Signatures in Global and National Commerce Act (E-Sign Act),
15 U.S.C. 7001 et seq., may be helpful to avoid confusion. Accordingly,
the Agencies propose to add an explicit reference to the E-Sign Act in
comment 22(b)-3.
Section --.23--Unfair Acts or Practices Regarding Allocation of
Payments
When different annual percentage rates apply to different balances
on a consumer credit card account, Sec. --.23 requires institutions to
allocate any amount paid by the consumer in excess of the required
minimum periodic payment (the excess payment) among the balances using
one of two methods. The institution may apply the excess payment first
to the balance with the highest annual percentage rate and any
remaining portion to the other balances in descending order based on
the applicable rate (the high-to-low method). Alternatively, the
institution may allocate the excess payment among the balances in the
same proportion as each balance bears to the total balance (the pro
rata method).
When the Agencies originally proposed to address payment
allocation, the proposed rule contained provisions specifically
addressing accounts with a balance subject to a deferred interest
program.\4\ One of these proposed provisions would have permitted (but
not required) an existing practice by some institutions of allocating
excess payments first to a balance on which interest is deferred during
the last two billing cycles of the deferred interest period so that
consumers could pay off that balance and avoid assessment of the
accrued interest. See proposed Sec. --.23(b)(1)(ii), 73 FR 28916,
28942 (May 19, 2008). Some industry commenters supported this aspect of
the proposal, while others argued that it would require burdensome
changes to their systems. Some consumer group commenters argued that,
rather than allowing institutions to choose whether to apply excess
payments to deferred interest balances in the last two billing cycles,
this allocation method should be mandatory. Due to other concerns about
deferred interest plans, however, the January 2009 Rule did not include
this provision. See 74 FR 5519, 5527-5528.
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\4\ Many creditors offer deferred interest programs under which
consumers are not obligated to pay interest on purchases if those
purchases are paid in full by the end of a specified period. If the
purchases are not paid in full when the period ends, these programs
generally require the consumer to pay interest that has accrued on
the purchases during the period.
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As discussed in greater detail below with respect to Sec. --.24,
the Agencies propose to clarify that--so long as consumers receive
sufficient protections--institutions may continue to provide
promotional programs under which a consumer will not be obligated to
pay interest that accrues on a balance if that balance is paid in full
prior to a specified date or expiration of a specified period of time
(deferred or waived interest programs).\5\ One area in which
clarification is needed with respect to such programs is payment
allocation. Under the current version of Sec. --.23, if the deferred
or waived interest balance is not the only balance on the account, the
consumer would generally be required to pay off the entire outstanding
balance in order to avoid interest charges on the deferred or
[[Page 20808]]
waived interest balance.\6\ If the consumer is unaware of the need to
pay off the entire balance, the consumer would be charged interest on
the deferred or waived interest balance and thus would not obtain the
benefits of the promotional program.
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\5\ For purposes of this SUPPLEMENTARY INFORMATION, a waived
interest program includes a promotional program where interest is
refunded if a balance is paid in full within a specified period of
time.
\6\ For example, assume that a consumer credit card account has
a $2,000 purchase balance with a 20% annual percentage rate and a
$1,000 balance on which interest accrues at a 15% annual percentage
rate, but the consumer will not be obligated to pay that interest if
that balance is paid in full by a specified date. Regardless of
whether the institution uses the high-to-low allocation method or
the pro rata allocation method, the consumer would be required to
pay $3,000 in order to avoid interest charges on the $1,000 balance.
Indeed, under the current version of Sec. --.23, the only
circumstance in which the consumer could pay off the $1,000 balance
without also paying off the $2,000 purchase balance would be if the
$1,000 balance had a higher annual percentage rate than the $2,000
purchase balance and the institution chose to use the high-to-low
method.
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To ensure that consumers are adequately protected, the Agencies
propose to amend Sec. --.23 to require institutions to allocate excess
payments first to deferred or waived interest balances during the last
two billing cycles of the promotional period. As noted above, this is
consistent with the current practice of many institutions with respect
to deferred interest plans and is generally beneficial to consumers
insofar as it enables them to avoid interest charges by paying off the
accrued interest balance in full prior to expiration without paying off
all other balances on the account.\7\ Accordingly, the Agencies propose
to move the provisions in the current version of Sec. --.23 to Sec.
--.23(a), to place the new provision for deferred or waived programs in
Sec. --.23(b), and to renumber the existing commentary accordingly.
The Agencies also propose to add a new example in comment 23(a)-1
(proposed comment 23(a)(1)-1) illustrating the application of proposed
Sec. --.23(b). In addition, elsewhere in today's Federal Register, the
Board has proposed to amend the disclosure requirements for periodic
statements in Regulation Z, 12 CFR 226.7, to ensure that consumers are
informed of the amount of interest accrued on the deferred or waived
balance and the date by which that balance must be paid in full to
avoid those accrued interest charges.\8\
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\7\ As discussed above, for purposes of this proposal, the
Agencies continue to rely on the legal authority and analysis
contained in the January 2009 Rule. In particular, with respect to
the proposed amendment to Sec. --.23, the Agencies rely on the
legal analysis regarding unfair payment allocation practices at 74
FR 5514-5517. In addition, the Agencies note that failing to
allocate excess payments first to deferred or waived interest
balances during the last two billing cycles of the promotional
period appears to cause substantial consumer injury insofar as a
different allocation method would result in the assessment of
accrued interest (unless the consumer pays off all balances on the
account). Because one of the intended purposes of a credit card
account is to finance purchases over multiple billing cycles, it
would be unreasonable to expect consumers to avoid accrued interest
charges on a deferred or waived interest balance by paying off all
balances on the account. Finally, failing to comply with the
proposed amendment does not appear to create any benefits for
consumers that would outweigh the injury. Indeed, the Agencies
understand that the payment allocation practices of many
institutions offering deferred or waived interest programs already
comply with the proposed amendment.
\8\ Specifically, the Board is proposing to amend 12 CFR 226.7
comment 7(b)-1 to require creditors offering deferred or waived
interest programs to disclose on the periodic statement the balance
subject to the program and the amount of interest that has accrued
on that balance. In addition, the Board is proposing to add a new 12
CFR 226.7(b)(14) that would require creditors to state on the front
of the periodic statement for the two billing cycles immediately
preceding expiration of the promotional period the date on which the
period expires and that the deferred or waived interest balance must
be paid in full by a specific date in order to avoid accrued
interest charges.
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Furthermore, the Agencies propose to amend comment 23-6 to clarify
that, for purposes of Sec. --.23, a balance on which interest will not
be charged if the balance is paid in full prior to expiration of a
specified period should be treated as a balance with an annual
percentage rate of zero rather than a balance with the rate at which
interest accrues during the promotional period (the accrual rate). As
an initial matter, treating the rate as zero is consistent with the
nature of the deferred or waived interest program insofar as the
consumer will not be obligated to pay any accrued interest if the
balance is paid in full prior to expiration. In addition, because Sec.
--.23 only applies when different annual percentage rates apply to
different balances on the account, using the accrual rate for purposes
of Sec. --.23 could significantly narrow the protections of the
payment allocation rules. Specifically, when the accrual rate for a
deferred or waived interest balance is the same as the rate that
applies to purchases (which the Agencies understand is often the case)
and there are no other balances on the account, Sec. --.23 would not
apply if the accrual rate was used. For example, if an account has a
$1,000 purchase balance with an annual percentage rate of 15% and a
$2,000 balance on which interest accrues at 15% but will not be charged
if that balance is paid in full within a specific period of time, Sec.
--.23 would not apply if the accrual rate of 15% was the applicable
rate for the $2,000 balance for purposes of payment allocation. The
Agencies believe that, in these circumstances, consumers should be
afforded the protections in Sec. --.23 (and, in particular, the
protections in proposed Sec. --.23(b)).
In addition, for purposes of the high-to-low allocation method in
Sec. --.23(a)(1), treating the rate on this type of promotional
balance as zero during the accrued interest period ensures that excess
payments will be applied first to balances on which interest is being
charged, which will generally result in lower interest charges if the
consumer pays the deferred or waived interest balance in full prior to
expiration of the promotional period. Thus, using the above example,
the amendments to comment 23-6 would clarify that an institution using
the high-to-low method would allocate excess payments to the $1,000
purchase balance before the $2,000 balance until the last two billing
cycles of the accrued interest period (when proposed Sec. --.24(b)
would require that excess payments be applied first to any remaining
portion of the $2,000 balance). Although treating the rate on the
deferred or waived interest balance as zero could prevent consumers who
wish to pay off that balance in installments over the course of the
promotional period from doing so, the Agencies believe that, on
balance, this treatment produces the best overall outcome for consumers
when the high-to-low allocation method is used.\9\
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\9\ The Agencies note that, if the institution uses the pro rata
allocation method, a proportionate amount of the excess payment will
be applied to the deferred or waived interest balance each month
during the promotional period.
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Finally, proposed comment 23(b)-1 would clarify that Sec. --.23(b)
applies to promotional programs under which the consumer is not
obligated to pay interest that accrues on a balance if that balance is
paid in full prior to the expiration of a specified period of time, not
to grace periods offered by the institution.
Requests for Comment
The Agencies request comment on:
Whether the provision in proposed Sec. --.23(b) regarding
balances on which interest will not be charged if the balance is paid
in full by a specified date should apply during the last two billing
cycles of the deferred or waived interest period or during a longer or
shorter time period.
Whether proposed Sec. --.23(b) should apply to a grace
period offered by the institution. In particular, the Agencies request
comment on whether institutions offer grace periods that only require
consumers to pay certain balances in full each billing cycle (rather
than the entire balance) and, if so, whether proposed Sec. --.23(b)
should
[[Page 20809]]
permit institutions to apply excess payments to those balances first.
Section --.24--Unfair Acts or Practices Regarding Increases in Annual
Percentage Rates
Section --.24(a) requires institutions to disclose, at account
opening, the annual percentage rates that will apply to each category
of transactions on a consumer credit card account. In addition, Sec.
--.24(a) prohibits institutions from increasing those rates unless
specifically permitted by one of the exceptions in Sec. --.24(b).
As an initial matter, the Agencies understand that clarification is
needed regarding the meaning of ``category of transactions'' for
purposes of Sec. --.24. Accordingly, the Agencies propose to add a new
comment 24-3 to clarify that, for purposes of Sec. --.24, a ``category
of transactions'' is a type or group of transactions to which an annual
percentage rate applies that is different than the annual percentage
rate that applies to other transactions. For example, purchase
transactions, cash advance transactions, and balance transfer
transactions are separate categories of transactions for purposes of
Sec. --.24 if an institution applies different annual percentage rates
to each. Furthermore, if, for example, the institution applies
different annual percentage rates to different types of purchase
transactions (such as one rate for purchases of gasoline and a
different rate for all other purchases), each type constitutes a
separate category of transactions for purposes of Sec. --.24.\10\
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\10\ As noted below, the Agencies request comment on whether
institutions establish separate categories of transactions based on
factors other than annual percentage rates and, if so, for what
reasons.
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In addition, the Agencies understand there is some confusion
regarding whether certain changes to a consumer credit card account
constitute an ``account opening'' for purposes of Sec. --.24 generally
and, in particular, the general prohibition on increasing rates during
the first year after account opening. Accordingly, the Agencies propose
to add a new comment 24-4 clarifying that, when a consumer has a credit
card account with an institution and the consumer opens a new credit
card account with the same institution (or its affiliate or
subsidiary), the opening of the new account constitutes an ``account
opening'' for purposes of Sec. --.24 if the consumer retains the
ability to obtain additional extensions of credit on both accounts.
Thus, for example, if a consumer opens a credit card account with an
institution on January 1 of year one and opens a second credit card
account with that institution on July 1 of year one, the opening of the
second account constitutes an account opening for purposes of Sec.
--.24 so long as the consumer can engage in transactions using either
account. This is the case even if the consumer transfers a balance from
the first account to the second. Thus, because the institution has two
separate account relationships with the consumer, the general
prohibition in Sec. --.24 on increasing rates during the first year
after account opening would apply to the opening of the second account.
In contrast, the comment would clarify that an account has not been
opened for purposes of Sec. --.24 when an institution replaces one
consumer credit card account with another consumer credit card account
(such as when a retail credit card is replaced with a cobranded general
purpose card that can be used at a wider number of merchants) or when
an institution consolidates or combines a credit card account with one
or more other credit card accounts into a single credit card account.
As discussed above, the Agencies believe that these transfers should be
treated as a continuation of the existing account relationship rather
than the creation of a new account relationship. Similarly, the comment
would also clarify that the replacement of an acquired credit card
account does not constitute an ``account opening'' for purposes of
Sec. --.24. Thus, in these circumstances, the general prohibition in
Sec. --.24 on increasing rates during the first year after account
opening would not apply. However, when a replacement or consolidation
occurs during the first year after account opening, proposed comment
24-4 would clarify that the institution may not increase an annual
percentage rate in a manner otherwise prohibited by Sec. --.24.\11\
Similarly, the other protections in Sec. --.24 (such as the
limitations on repayment of protected balances in Sec. --.24(c)) would
still apply following the replacement or consolidation.
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\11\ For example, assume that, on January 1 of year one, a
consumer opens a consumer credit card account with a purchase rate
of 15%. On July 1 of year one, the account is replaced with a
consumer credit card account issued by the same institution, which
offers different features (such as rewards on purchases). Under
these circumstances, the institution could not increase the annual
percentage rate for purchases to a rate that is higher than 15%
pursuant to Sec. --.24(b)(3) until January 1 of year two (which is
one year after the first account was opened).
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Finally, the Agencies understand that the replacement of one
consumer credit card account with another generally is not
instantaneous. If, for example, a consumer requests that a credit card
account with a $1,000 balance be upgraded to a credit card account that
offers rewards on purchases, the second account may be opened
immediately or within a few days but, for operational reasons, there
may be a delay before the $1,000 balance can be transferred and the
first account can be closed.\12\ Accordingly, the Agencies solicit
comment on whether the appropriate amount of time for the replacement
of one consumer credit card account with another is 15 days, 30 days,
or a different period.\13\
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\12\ As discussed above, the proposed commentary to Sec. --.21
would clarify that, in these circumstances, the institution could
not increase the annual percentage rate that applies to the $1,000
balance unless otherwise permitted by Sec. --.24.
\13\ Proposed comment 24-4 provides 15 days and 30 days as
alternatives.
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Section --.24(a) General Rule
The Agencies also understand that there is some confusion regarding
the relationship between comment 24(a)-1 and Regulation Z, 12 CFR
226.6(b)(2)(i)(D) with respect to the disclosure of penalty rates.
Specifically, comment 24(a)-1 states that institutions cannot satisfy
the disclosure requirements in Sec. --.24(a) by disclosing a range of
annual percentage rates or that a rate will be ``up to'' a particular
amount. In contrast, when more than one penalty rate may apply, 12 CFR
226.6(b)(2)(i)(D) permits creditors to disclose ``the highest rate that
could apply, instead of disclosing the specific rates or the range of
rates that could apply.'' Because the disclosure requirements in Sec.
--.24(a) are intended to ensure that consumers receive notice at
account opening of the specific annual percentage rates that will apply
to the categories of transactions on the account, those requirements do
not apply to rates that may or may not apply depending on a particular
event or occurrence (such as penalty rates) or rates that may be
applied at the institution's discretion. Therefore, the Agencies
propose to amend comment 24(a)-1 accordingly. The Agencies note,
however, that this clarification is limited to the disclosure
requirements in Sec. --.24(a) and does not alter Sec. --.24(a)'s
general prohibition on applying penalty rates or other contingent rates
unless specifically permitted by Sec. --.24(b).
The Agencies also propose the following clarifications and
technical corrections to the commentary to Sec. --.24(a):
Amend the example in comment 24(a)-2.i to clarify that the
institution
[[Page 20810]]
disclosed a penalty rate at account opening.
Amend the example in comment 24(a)-2.iii to clarify that
the 12 CFR 226.9(g) notice states that, if the consumer becomes more
than 30 days late on the account, the penalty rate will apply to all
balances on the account.
Amend the example in comment 24(a)-2.iii.C to correct a
typographical error.
Section --.24(b)(1) Account Opening Disclosure Exception
Section --.24(b)(1) provides that an annual percentage rate for a
category of transactions may be increased to a rate disclosed at
account opening upon expiration of a period of time disclosed at
account opening. Under this exception, if, for example, an institution
discloses at account opening that a 5% rate will apply to purchases for
six months and that a 15% rate will apply thereafter, the institution
can increase the rate on the existing purchase balance and on new
purchases to 15% after six months. These plans are sometimes referred
to as ``stepped rates.''
Comment 24(b)(1)-1 states that, because Sec. --.24(b)(1) is
limited to increased rates that will apply after a specified period of
time, the exception does not permit application of increased rates that
are disclosed at account opening but are contingent on a particular
event or occurrence or may be applied at the institution's discretion.
For example, as illustrated in comment 24(b)(1)-1.i, Sec. --.24(b)(1)
does not permit an institution to apply an increased penalty rate when
a consumer makes a late payment even if the institution disclosed that
rate at account opening. For clarity, the Agencies propose to move this
language into the text of Sec. --.24(b)(1). The Agencies also propose
to amend comment 24(b)(1)-1 to clarify that the examples illustrate the
application of Sec. --.24, rather than just Sec. --.24(a).
Comment 24(b)(1)-2 clarifies that nothing in Sec. --.24 prohibits
an institution from assessing interest due to the loss of a grace
period to the extent consistent with the prohibition on two-cycle
billing in Sec. --.25. Because the Agencies understand that there is
some confusion regarding the relationship between Sec. --.24 and the
provision of a grace period, the Agencies propose to add language to
this comment clarifying that an institution has not reduced an annual
percentage rate on a consumer credit card account for purposes of Sec.
--.24 if the institution does not charge interest on a balance when the
consumer pays that balance in full prior to the expiration of a grace
period. In addition, for organizational purposes, the Agencies propose
to redesignate this comment as 24-2 and renumber comment 24(b)(1)-3
accordingly.
Finally, the Agencies understand that there is some confusion as to
whether an institution waives the right to impose an increased rate
pursuant to Sec. --.24(b)(1) if it does not do so immediately upon
expiration of the specified time period. As a general matter, because
Sec. --.24 is intended to increase predictability and transparency for
consumers, the exceptions in Sec. --.24(b) do not permit institutions
to retain the right to increase a rate indefinitely and at their
discretion. For example, if at account opening an institution discloses
a stepped rate of 15% on purchases for one year and 20% thereafter, the
institution can apply a lower rate of 17% at the end of the year but,
if it wants to retain its right under Sec. --.24(b)(1) to apply the
20% rate to purchases made during the first year, it must disclose to
the consumer (pursuant to 12 CFR 226.9(c)) how long the 17% rate will
apply and that the 20% rate will apply thereafter so that the consumer
can make informed decisions when using the card. See comment 24(b)(1)-3
(proposed comment 24(b)(1)-2)).
The Agencies understand, however, that applying an increased rate
on a specific date can present operational difficulties when that date
falls in the middle of a billing cycle. Accordingly, to address this
concern, the Agencies propose to add a new comment 24(b)-1 clarifying
that, if Sec. --.24(b) permits an institution to apply an increased
annual percentage rate on a date that is not the first day of a billing
cycle, the institution may delay application of the increased rate
until the first day of the following billing cycle without
relinquishing the ability to apply that rate.\14\
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\14\ For example, assume that, at account opening on January 1,
an institution discloses that a 10% rate will apply to purchases for
six months and a 15% rate will apply thereafter. The first day of
the billing cycle for the account is the fifteenth of the month. If
the six-month period expires on July 1, the institution may delay
application of the 15% rate until July 15 without relinquishing its
ability to apply that rate under Sec. --.24(b)(1).
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Section --.24(b)(3) Advance Notice Exception
Section --.24(b)(3) provides that an annual percentage rate for a
category of transactions may be increased pursuant to a notice under 12
CFR 226.9(c) or (g) for transactions that occur more than seven days
after provision of the notice. The Agencies understand that there has
been some confusion regarding the interaction between this seven-day
period in Sec. --.24(b)(3) and the requirement in 12 CFR 226.9(c) and
(g) that notice of an increased rate be provided at least 45 days prior
to imposition of the increased rate. As illustrated in the examples in
comment 24(b)(3)-3, the distinction is that the institution may apply
the increased rate to any transaction that occurs after the seventh day
following provision of the notice, but it must wait 45 days to begin
accruing interest at that rate. The reason for this distinction is that
the two time periods serve different purposes. The seven-day period is
intended to ensure that the consumer receives the notice and is aware
of the increased rate before engaging in transactions to which that
increased rate will eventually apply (unless the consumer transfers or
pays off the balance). See 74 FR 5531. In contrast, the 45-day period
is intended to give the consumer sufficient time to evaluate whether to
continue using the credit card account at the increased rate or whether
better terms can be obtained elsewhere. See 74 FR 5344-5356. For
additional clarity, the Agencies propose to amend comment 24(b)(3)-2 to
state that, when calculating interest charges, Sec. --.24(b)(3) does
not permit an institution to reach back to days before the effective
date of the rate increase under 12 CFR 226.9(c) or (g)--in other words,
the date 45 days after provision of the notice.
The Agencies also propose to amend comment 24(b)(3)-2 to clarify
when a transaction is deemed to have occurred for purposes of Sec.
--.24(b)(3). Specifically, the current version of comment 24(b)(3)-2
states that an institution may apply a rate increased pursuant to Sec.
--.24(b)(3) to transactions that are authorized within seven days--but
are settled more than seven days--after provision of the notice. The
Agencies understand, however, that this distinction has created some
confusion because, for example, authorization may not be obtained for
all transactions and because the term ``settled'' could refer to
different points in the payment process, including settlement between
the acquirer and the merchant or settlement between the consumer and
the card issuer. Accordingly, for consistency and clarity, the Agencies
propose to amend comment 24(b)(3)-2 to clarify that when a transaction
occurred for purposes of Sec. --.24(b)(3) is determined by the date of
the transaction (without regard to when the transaction is authorized,
settled, or posted to the consumer's account). In addition, the
Agencies would clarify that, when a merchant places a ``hold''
[[Page 20811]]
on the available credit on an account for an estimated transaction
amount when the actual transaction amount will not be known until a
later date, the date of the transaction for purposes of Sec.
--.24(b)(3) is the date on which the merchant determines the actual
transaction amount. The Agencies also propose to amend the examples in
comment 24(b)(3)-3 for consistency with these proposed changes.
In addition, the Agencies propose to amend Sec. --.24(b)(3) and
its commentary to reflect that notice of an increased rate may be
provided under 12 CFR 226.9(b), which applies to supplemental access
devices (such as convenience checks) and additional features added to
the account after account opening. 12 CFR 226.9(b) requires creditors
to disclose the rates and other key terms applicable to the device or
feature before the consumer uses the device or feature for the first
time. For example, 12 CFR 226.9(b)(3)(A) requires that creditors
providing convenience checks to which a temporary promotional rate
applies disclose key terms on the front of the page containing the
checks, including the promotional rate, the period during which the
promotional rate will be in effect, and the rate that will apply after
the promotional rate expires. Thus, unlike rates increased pursuant to
a 12 CFR 226.9(c) and (g) notice, the seven-day period is not necessary
for rate increases disclosed pursuant to 12 CFR 226.9(b) because the
device or feature will not be used before the consumer has received
notice of the applicable rates and terms. Accordingly, the Agencies
propose to amend Sec. --.24(b)(3) to provide that increased rates
disclosed pursuant to 12 CFR 226.9(b) must not be applied to
transactions that occurred prior to provision of the notice. Section
--.24(b)(3) would continue to provide that increased rates disclosed
pursuant to 12 CFR 226.9(c) or (g) must not be applied to transactions
that occurred within seven days after provision of the notice. The
Agencies would also clarify in comment 24(b)(3)-2 that, if a rate
increase is disclosed pursuant to both 12 CFR 226.9(b) and 12 CFR
226.9(c), that rate may only be applied to transactions that occur more
than seven days after provision of the 12 CFR 226.9(c) notice. In
addition, the Agencies would add an illustrative example in new comment
24(b)(3)-4.iv.
Finally, the Agencies understand that clarification is needed
regarding the application of discounted promotional rates to existing
accounts. As discussed above, Sec. --.24(b)(1) permits stepped rates
disclosed at account opening. In addition, comment 24(b)(3)-3 provides
some examples of how a stepped rate could be provided pursuant to a 12
CFR 226.9(c) notice. The Agencies did not, however, specifically
address circumstances in which a discounted promotional stepped rate is
offered after account opening. Consistent with comment 24(b)(3)-3, the
Agencies believe that, if the consumer receives advance notice of the
term of the discounted rate and the rate that will apply after that
term expires, a promotional stepped rate offer on an existing account
can provide the same benefits to consumers as a promotional stepped
rate offer at account opening so long as the offer cannot be used to
increase the rate that applies to pre-existing balances.
Accordingly, to clarify that such offers are permitted, the
Agencies propose to add a new comment 24(b)(3)-4 stating that nothing
in Sec. --.24 prohibits an institution from lowering the annual
percentage rate that applies to an existing balance or to new
transactions. The comment would further state, however, that, if a
lower rate is applied to an existing balance, the institution cannot
subsequently increase the rate on that balance unless it has provided
the consumer with advance notice of the increase pursuant to 12 CFR
226.9(b) or (c). This notice must state the period of time during which
the lower rate will apply (or the date until which that rate will
apply) and the rate that will apply after expiration of that period.
Furthermore, to ensure that the consumer receives notice of the offer
before engaging in transactions that are subject to that offer (and
will therefore eventually be taken to a higher rate), the comment would
clarify that, when an institution applies a decreased rate to
transactions that occurred prior to provision of the notice (or, in the
case of a 12 CFR 226.9(c) or (g) notice, transactions that occurred
within seven days after provision of the notice), the institution may
not subsequently increase the rate that applies to those transactions
to a rate that is higher than the rate that applied prior to the
decrease.\15\ Finally, the comment would provide illustrative examples
of stepped rate offers that would comply with these requirements.\16\
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\15\ For example, assume that the annual percentage rate for
purchases on an account is 15% and that, pursuant to 12 CFR
226.9(c), the institution provides notice on July 1 that a rate of
5% will apply to purchases until December 31, after which a rate of
17% will apply. If the institution applies the 5% rate to purchases
made on or before July 8, the institution may only increase the rate
on those purchases to a maximum of 15% on December 31.
\16\ For the same reasons, the Agencies propose to amend comment
24(b)(1)-3 (proposed comment 24(b)(1)-2) to clarify that
institutions may offer discounted stepped rates during the first
year after account opening so long as the rate that applies after
expiration of the discounted rate does not exceed the rate disclosed
at account opening for that category of transactions.
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Section --.24(b)(5) Workout Arrangement Exception
Section --.24(b)(5) provides that an annual percentage rate may be
increased due to the consumer's failure to comply with the terms of a
workout arrangement between the institution and the consumer, provided
that the annual percentage rate applicable to a category of
transactions following any such increase does not exceed the rate that
applied to that category of transactions prior to commencement of the
workout arrangement. This exception is intended to encourage
institutions to continue offering workout arrangements that reduce
rates for consumers in serious default, while also ensuring that a
consumer who enters into such an arrangement but is unable to comply
with its terms is not charged a rate that exceeds the rate that applied
prior to the arrangement. See 74 FR 5532.
Because the term ``workout'' has been used by the Agencies in other
contexts,\17\ the Agencies understand that there is some confusion as
to whether this exception also applies to temporary hardship
arrangements that assist consumers in overcoming financial difficultie