i. Under A§ 1026.4(b)(11)(ii), regarding a covered different credit score rating feature and a valuable asset ability of a prepaid profile being both easily accessible by a crossbreed prepaid-credit card as described A§ 1026.61, any fee or fee imposed regarding advantage feature from the prepaid accounts try a fund fee with the level that amount of the charge or charge exceeds comparable charges or fees imposed on prepaid account in identical prepaid accounts plan which do not has a covered split credit score rating function available by a hybrid prepaid-credit credit. This comment produces advice pertaining to equivalent fees under A§ 1026.4(b)(11)(ii) for your two types of credit score rating extensions on a covered split credit ability. 61(a)(2)(i)(B) and remark 61(a)(2)a€“4.ii. ii provides assistance for credit score rating extensions the spot where the hybrid prepaid-credit cards accesses credit score rating from the sealed separate credit ability for the duration of authorizing, settling, or perhaps finishing a transaction conducted utilizing the card to have items or providers, acquire earnings, or behavior person-to-person exchanges. iii provides guidance for credit extensions where a consumer draws or transfers credit from covered separate practical link credit ability outside of the span of a transaction executed making use of cards to get items or services, obtain cash, or make person-to-person transfers.

ii. Per purchase charges for a transaction definitely conducted to load or suck resources into a prepaid account from another resource are not similar for reason for A§ 1026.4(b)(11)(ii). To demonstrate:

A. believe a prepaid levels issuer charges $0.50 on prepaid profile without a sealed separate credit score rating element for each exchange that accesses funds inside the resource ability of the prepaid account. Also, think that the prepaid accounts issuer charges $0.50 per exchange throughout the advantage feature of prepaid account in identical prepaid regimen in which the crossbreed prepaid-credit credit accesses credit score rating from a covered different credit score rating feature during the course of a transaction. In this case, the $0.50 per transaction fee imposed regarding house element for the prepaid profile with a covered individual credit ability is certainly not a finance fee.

Opinion 4(b)(11)(ii)a€“1

B. presume same information like in part an overhead, apart from presume the prepaid accounts issuer charges $1.25 on the house ability of a prepaid account fully for each purchase where hybrid prepaid-credit credit accesses credit through the sealed different credit feature during the course of the purchase. In this case, the excess $0.75 was a finance fee.

C. Assume a prepaid account issuer charges $0.50 on prepaid profile without a covered separate credit score rating function per purchase that accesses funds from inside the resource element in the prepaid accounts. Believe also your prepaid profile issuer charges both a $0.50 per transaction fee and a $1.25 move charge regarding resource element of prepaid profile in the same prepaid plan where crossbreed prepaid-credit cards accesses credit from a covered individual credit feature in the course of a transaction. e., a combined charge of $1.75 per purchase) must be compared to the $0.50 per deal fee to access resources during the resource function with the prepaid account without a covered individual credit feature. Correctly, the $1.25 unwanted try a finance cost.

See A§ 1026

D. Assume exact same knowledge as in paragraph C above, except that believe the prepaid account issuer also charges lots fee of $1.25 whenever resources is transferred or packed from a separate investment profile, instance from in initial deposit membership via a debit cards, throughout a deal on prepaid records without a sealed split credit function, as well as recharging a $0.50 per purchase cost. The $1.25 extra in paragraph C continues to be a finance fee because load or transfer charges that are recharged about investment ability of prepaid be the cause of credit score rating from the sealed split credit feature become in comparison and then per deal charge implemented for accessing resources inside house element of the prepaid be the cause of prepaid profile without such a credit ability. Per transaction costs for a transaction which performed to stream or suck funds into a prepaid profile from various other origin commonly comparable for purposes of A§ 1026.4(b)(11)(ii).