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March 05, 2010

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Comments

Dianna

With regard to the 6-month "lookback," did you read anything that gives exception when the member initiated the action that resulted in the increased rate? If the rate was increased due to a penalty resulting from an institution initiation, it makes more sense . . . right?

Anthony Demangone

I don't see any exception.

If a card issuer increases an
annual percentage rate that applies to a credit card account under an open-end (not homesecured)
consumer credit plan, based on the credit risk of the consumer, market
conditions, or other factors...

The "other factors" would appear to capture just about any rate increase as I read this.

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