1026.7 - Periodic Statement Flashcards
Previous Balance
Account balance outstanding at beginning of billing cycle
- Credit balances must be disclosed as such
- In multi-feature plan, previous balance can be disclosed as aggregate or separated (w/ total optional)
Identification of Transactions
Must be in accordance w/ 1026.8 (ID’ing trxns)
- Do not need to be in order certain way but per 26.7, must grouop all FaFC separately from trxns
- Fees from other FIs for ATM use need not be separate
Credits
Any credit to account during billing cycle including amt and date.
- Don’t have to describe each credit type unless related to FCBA
- Total cumulation of credits not required.
Periodic Rates
Each rate, expressed as APR, that can be used to assess interest and using the term Annual Percentage Rate. Must also disclose the balance(s) it’s applicable to. Not req. to disclose min. balance that triggers FC
Disclosing rates whether or not actually applied
Must disclose each rate per feature (e.g., purchases, cash adv) even if no trxn per feature are conducted. Only need to discloses that could’ve been imposed need to be disclosed. Rates applied to previous fees do not need disclosed separately.
Balance that Finance Charge is Computed
Amt of balance that rate was applied to AND an explanation of how that balance was determined. Must use term “Balance Subject to Interest Rate.” FI has option to provide name of computation method if used from 26.60(g) and provide TF phone # where AH can obtain info. Do not need to give every single piece of info on method.
Computing Applicable Balance w/o Credits and Payments
Must disclose if balance is determined w/o first deducting credits/payments. Must also disclose total of credits/payments. Disclosure of credits can be done by meeting requirements of disclosing overall credits in statement (separate) and then stating which ones may not be applicable (e.g., after certain date)
Multi-featured plans for Balance Applicability
Must disclose a separate balance to which a per. rate was applied for each feature. Does not affect how many balances the creditor must disclose.
Daily Rate on Daily Balance Examples (i.e., FC computed on balance each day by one more or more periodic rate)
- Balance which it was applicable can be stated as for any # of rates
a. A balance for each day in billing cycle
b. Balance for each day in cycle where balance changes
c. The ADB during cycle, where FI can explain that ADB is or can be multiplied by number of days in BC and then rate applied.
One computation method for multiple and different balances
It is allowed to only disclose one balance computation method but all applicable balances must still both be disclosed.
Balance Computation Disclosure per Feature
If balance computation method chosen from safe harbor (26.60) is applicable to purchases, the FI must update the naming convention to be applicable to that feature. I.e., Average Daily Balances (including cash advances) if included (or excluding) if not included.
Charges Imposed as part of plan (FaFC)
Must be disclosed in proximity to actual transactions in format G-18A
- Interest: Must use term “Interest Charge” under heading “Interest Charged”, itemized and totaled. Statement period and calendar year to date.
- Fees: Must be under the heading, “Fees” identified consistent with feature or type. Itemized and totaled. Must be disclosed for statement period and calendar year to date. (G-18A)
Monthly Statements and Reflecting Year-to-Date Totals (FaFC)
Two option 1) May disclose calendar YTD at end of calendar year by separately aggregating FaFC starting with period of Jan and ending in Dec. or; 2) Same as 1 but Dec-Nov. If previous cycle FaFC waived then it is up to FI reflect as adjustments in totals but may not be adjusted for current cycle total.
Minimum charge instead of interest
If FI imposes min. charge if interest accrued does not exceed minimum interest threshold, then that charge must be designated as a fee on the statement and must show “$0 interest” on same stmt.
FaFC Listing on Acquired and/or Upgrade Accounts
FI must include as applicable, FaFC that were imposed by prior FI in new totals of acquired plan. Can be provide separate totals (before/after acquisition)
CIT / Increased Penalty Rate
If either a CIT or Pen. Rate increase are provided on/with a statement, it must be in same format as described in 1026.9. They should be provided at the front of stmt.
Grace Period
Date or time period which new balance (or any portion, if app) must be paid to avoid additional FC. Should be described similarly to that of origination disclosures.
Address for Billing Errors
Can be provided in Billing Rights Summary or independently. Can provide email, telephone or other but physical address must be clear and conspicuous.
Closing Date of Cycle
Must be disclosed in close proximity to min. payment due date.
Due Date
Shall be the same day of each month. For example, 25th of each month, not third Tuesday of each month. Creditor can change periodically, as long as it will be consistent.
Late payment costs
Should be disclosed on each statement including late fees (or range of) and any late payment rate increases (or range of).
- Does not apply to charged off accounts where entire balance is due.
Courtesy Period for Lateness
Not required to be disclosed but should be consistent.
Repayment Disclosures: Min Pymt,
- Must disclose the fact that only making min pymt will lead to more interest and take longer to pay off balance.
- Min pymt time estimate in years & months if greater than two years
- # to credit counseling services (# must provide 3 CCSs, can be automated)
- total payoff rounded to nearest dollar w/ statement based on current balance
Repayment Disclosures: 36 months
Must disclose estimated monthly pymt for 36 month payoff to nearest dollar/cent (consistency)
Statement of payoff in 3 years if adhere to above
Total cost estimate for 36 month payoff
Savings estimate for 36 month payoff
Exclusions to 36 month payoff disclosures
If min pymt estimate to pay off balance is projected to take less than three years
If the calculated 36 month payment is less than the min due of the statement
Negative or No Amortization Disclosures
- Disclo stating that balance will never be paid off in event of min pymt only, even if no more charges posed (word for word)
- Disclo that making more than min pymt means less interest
- 36 month disclosures
- # for credit counseling services
Min Payment Disclosures Exclusions
- Two consec. billing cycles of balance being paid off
- Charge card requiring full balance pymt
- Balance that will be covered by min due
Credit Counseling Services
Cannot provide marketing information to consumers who request CCS info
Must provide info of 3 services approved by US Trustees
Telephone numbers for access must be prominently disclosed
Deferred Interest
Date of which deferred interest balance must be paid in order to avoid rolling interest must be disclosed on front page o f any statement issued during deferred period
