Personal Lines Of Credit are subject to MAPR recalculation each billing cycle, correct?

There's some discussion that PLOCs are not subject to the recalculation because it was not given the same delayed implementation like credit cards were.

I believe the delay was due to the fact PLOCs are typically in our own system, whereas credit cards likely required card merchants - but the Rule is clear that any open-end credit is subject to a MAPR calcuation each billing cycle, and that only credit cards have the bona fide fee provision. I wanted to double-check, though.

Any best guesses on whether we should recalcuate the MAPR each billing on a PLOC?

As much as I understand MLA, PLOCs need to have the MAPR calculated each billing cycle per 32 CFR 232(c)(2)(ii). The only effective date delay I am aware of was for credit cards. At my previous employer, we started PLOC calculations in October 2016 and credit cards in October 2017.

https://www.ecfr.gov/cgi-bin/retrieveECF...L#se32.2.232_14