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My bank offers credit cards with a variable based on a stated index and margin after an introductory rate. May the bank provide in the account opening disclosures the introductory rate and a range of rates that may apply after the introductory period? 

My bank offers credit cards with an introductory rate for a set period after which the rate will be variable based on a stated index and margin. Given the fact that the bank cannot know what the rate will be until after the introductory period, may the bank provide in the account opening disclosures the introductory rate and a range of rates, which will apply after the introductory period?

No. Per §1026.6(b)(2)(i)(B) of Regulation Z, “If the initial rate is an introductory rate… the creditor must disclose the rate that would otherwise apply to the account...In a variable-rate account, the creditor must disclose a rate based on the applicable index or formula in accordance with the accuracy requirements of paragraph (b)(4)(ii)(G) of this section.” Paragraph (b)(5)(ii)(G) states that a rate is accurate if it is as of a specified date and the rate was in effect within 30 days preceding the date of the disclosures. Therefore, for purposes of the account opening disclosures both the introductory rate as well as a non-introductory rate should be provided. (July 2020)

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