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December 17, 2009

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Comments

Joanne

Does the new TIS balance disclosure requirements apply to the "open to buy" balance sent for debit card purchasing?

Anthony Demangone

I'm not sure what that is. Is it a balance disclosed to the member through an automated system? If so, then it would appear to be covered. If not, then not.

Joanne

Currently Card Processors (and core processors) allow their financial institutions to combine checking with savings and line of credit balances into an "open to buy" bucket for POS authorizations. I doubt that processors are able to send an "open to buy" just for purchasing and separate balances to ATM's - so I am thinking these balances can no longer be combined. Financial institutions will need to contact their processors and make the change to comply with TIS if that is the case - right?

Anthony Demangone

Again, I can't say based on your question. Is this balance disclosed to the member via an automated system? If so, it could be covered. Second, if it is disclosed to the consumer, does it include an overdraft balance as outlined in the reg? I'm not sure that it does. It sounds like it simply combines savings and share draft balances.

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