We are are revision credit card applications and disclosures. When researching information on BOL, I'm finding discussions relating to a font size of "12 points" for fees.....
Not sure when that question was asked......

For some reason I'm remember the "18" point font size or at least something larger thanb 12??? Can anyone help by pointing me in the right direction.

As of 7-1-10 changes it will go from 18 to 16 for the Purchase/Balance Transfers. Cash Advance/Penalties and the like have no restrictions, but must be bold. This is all laid out in the credit card section on applications and solicitations inReg Z.

10 point font for everything other than APRs. Search the 1155 pages for "font", (around p. 820) or check out the Commentary to 226.5(a)(1)....

Okay, I'm confused. Current commentary suggests 12, but no less than 8. Effective 7-2010, I do not even see that reference. Just that the primarly APR went from 18 to 16?!?

p. 820-821/1155: "3. Clear and conspicuous—readily noticeable standard. To meet the readily noticeable standard, disclosures for credit card applications and solicitations under § 226.5a, highlighted account-opening disclosures under § 226.6(b)(1), highlighted disclosures on checks that access a credit card account under § 226.9(b)(3), highlighted change-in-terms disclosures under § 226.9(c)(2)(iv)(D), and highlighted disclosures when a rate is increased due to delinquency, default or penalty pricing under § 226.9(g)(3)(ii) must be given in a minimum of 10-point font. (See special rule for font size requirements for the annual percentage rate for purchases under §§ 226.5a(b)(1) and 226.6(b)(2)(i).)"

For July 2010, I beleive it is under 226.5a (maybe commentary) that in order to be clear and conspicuous the font size must be 10 pt, except for Purchase APR of 16 pt.

I have yet to find the 10 pt. only the 16...grrrr.

Phoenix, would you mind posting a link to the FR you just quoted from?

This is all I actually see!

The annual percentage rate for purchases disclosed pursuant to this paragraph shall be in at least 16-point type, except for the following: Oral disclosures of the annual percentage rate for purchases; or a penalty rate that may apply upon the occurrence of one or more specific events.


3. Clear and conspicuous standard. See comment 5(a)(1)–1 for the clear and conspicuous standard applicable to §226.5a disclosures.

5. Highlighting of annual percentage rates and fee amounts. i. In general. See Samples G–10(B) and G–10(C) for guidance on providing the disclosures described in §226.5a(a)(2)(iv) in bold text. Other annual percentage rates or fee amounts disclosed in the table may not be in bold text. Samples G–10(B) and G–10(C) also provide guidance to issuers on how to disclose the rates and fees described in §226.5a(a)(2)(iv) in a clear and conspicuous manner, by including these rates and fees generally as the first text in the applicable rows of the table so that the highlighted rates and fees generally are aligned vertically in the table.

And, the location highlighted above? I can't find that scheme anywhere.

I found this under the 226.5 General Disclosure commentary, not the 226.5a section I previously recalled:


3. Clear and conspicuous—readily noticeable standard . To meet the readily noticeable standard, disclosures for credit card applications and solicitations under §226.5a, highlighted account-opening disclosures under §226.6(b)(1), highlighted disclosures on checks that access a credit card account under §226.9(b)(3), highlighted change-in-terms disclosures under §226.9(c)(2)(iii)(B), and highlighted disclosures when a rate is increased due to delinquency, default or penalty pricing under §226.9(g)(3)(ii) must be given in a minimum of 10-point font. (See special rule for font size requirements for the annual percentage rate for purchases under §§226.5a(b)(1) and 226.6(b)(2)(i).)

apparently the updated commentary isn't yet published in the Alphabet soup...I guess I better dig out the FR.

Thanks!

Patience, my good friends. This troll is running as fast as he can to get the ABC Soup copy of Reg Z current. That's sort of difficult given that the 2/22 - 7/1/2010 amendments haven't even hit the Federal Register yet (what's up with THAT?) I've got the regulation itself brought current, and the Appendices (with a few missing PDF files at this date), and now I am toiling away at Supplement I (the Official Staff Interpretations or Commentary).

Sorry, John! I agree, it makes it rather difficult when they lag behind like that!

I think it just flat confused me because the main sections were updated, which is what I've been using in modeling our changes, but since the commentary wasn't I think I felt like I got "caught off guard" with the font stuff! LOL! I had just a little bit at 9 instead of 10 and I knew the APR was 16, so it wasn't a big deal. I'm just glad it's in the initial stage and not gone to print yet...they just need to slow down on all these major changes! grrrrrrrrrr


Oh..and thanks for all that ya'll do!!!!!!!!!!!

Update: The Appendices are updated (with a few of the links to graphic forms examples still to be established after the rule gets published in the FR), and I am slogging my way through the Commentary/Staff Interpretations. I just finished 226.6.