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#1683748 - 03/29/12 05:03 PM Credit Card "Schumer Box" TILA disclosures
query queen Offline
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Joined: Dec 2009
Posts: 15
In Reg Z, there are two model Credit Card forms in Appendix G: G10(A-C)for Application and Solicitations and also G17 A-C) Account Opening.They are substantially the same except for the Billing Rights Message on G17.I am perplexed on why there are two forms, since Reg Z requires a disclosure at application.
We have always given the G-10 disclosure at the same time a customer completes the credit card application. Do we need to give them an almost duplicate G-17 when they open the account? Our credit card vendor does provide an agreement detailing all aspects of the card itself, rate, late charge, minimum payment requirments, fees etc. to include a detailed description of how interest calculation method and the billing rights disclosure to the customer when the card is issued. Thank you.

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#1683906 - 03/29/12 07:53 PM Re: Credit Card "Schumer Box" TILA disclosures query queen
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,390
Yup.....you have to give the disclosure again (account opening disclosure) even if it's identical to the application disclosure. Our disclosure accompanies the credit card agreement document that the customer receives along with the card.
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