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June 17, 2010

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Comments

Jody

You guys are great! Thank you for doing this for us.

Kristina Brown

Thanks for adding this tidbit.

[Any card issuer using the "cost" method will have to reevaluate its determination of what those costs are, and the reasonable fee, every 12 months. That sounds like a lot of work, so I envision a super-majority of credit unions will simply use the safe harbor fee.]

Even though I completely agree with what was stated above. We are deciding to take the road less travelled by using the "cost" method. Do you have cost analysis templates or formulas that can assist?

Anthony Demangone

Hi Kristina,

I am not aware of any cost analysis templates. For now, all that is available is the Reg Z rule itself.

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