i. Under A§ 1026.4(b)(11)(ii), for a sealed separate credit function and a valuable asset element of a prepaid account which happen to be both obtainable by a hybrid prepaid-credit card as explained A§ 1026.61, any fee or fee imposed from the advantage ability on the prepaid membership are a fund cost toward degree the level of the charge or charge exceeds equivalent costs or expense implemented on prepaid reports in the same prepaid levels system that don’t bring a covered different credit feature easily accessible by a hybrid prepaid-credit cards. This remark supplies guidance with regards to equivalent charge under A§ 1026.4(b)(11)(ii) for any 2 kinds of credit score rating extensions on a covered separate credit score rating function. 61(a)(2)(i)(B) and opinion 61(a)(2)a€“4.ii. ii supplies guidelines for credit extensions in which the crossbreed prepaid-credit cards accesses credit score rating from covered different credit score rating ability during authorizing, deciding, or otherwise doing a transaction executed aided by the cards to acquire goods or providers, obtain funds, or run person-to-person transfers. iii provides direction for credit extensions where a consumer draws or exchanges credit score rating through the covered individual credit score rating ability outside of the length of a transaction performed using the cards to have products or providers, acquire finances, or conduct person-to-person exchanges.
ii. Per exchange fees for a purchase that is executed to weight or suck resources into a prepaid membership from various other supply aren’t similar for purposes of A§ 1026.4(b)(11)(ii). To illustrate:
A. Assume a prepaid membership issuer charges $0.50 on prepaid records without a sealed individual credit feature for each purchase that accesses resources inside resource function with the prepaid profile. In addition, believe that the prepaid account issuer charges $0.50 per exchange regarding the asset feature of prepaid account in identical prepaid regimen in which the hybrid prepaid-credit card accesses credit from a covered split credit function during a transaction. In such a case, the $0.50 per transaction cost enforced throughout the house feature with the prepaid levels with a covered separate credit element is not a finance cost.
Review 4(b)(11)(ii)a€“1
B. think exact same truth as with part an overhead, except that assume the prepaid levels issuer charges $1.25 regarding house feature of a prepaid take into account each exchange where in fact the hybrid prepaid-credit credit accesses credit score rating from the sealed split credit feature during the course of the deal. In such a case, the excess $0.75 is a finance fee.
C. believe a prepaid account issuer charges $0.50 on prepaid profile without a sealed individual credit feature for each exchange that accesses resources inside the investment feature in the prepaid profile. Think in addition your prepaid levels issuer charges both a $0.50 per transaction fee and a $1.25 move cost about investment feature of prepaid account in identical prepaid plan where the hybrid prepaid-credit cards accesses credit score rating from a covered separate credit element in the course of a transaction. e., a combined fee of $1.75 per exchange) should be set alongside the $0.50 per transaction cost to access resources in the advantage feature associated with the prepaid account without a covered Virginia title loan individual credit score rating element. Accordingly, the $1.25 unwanted is a finance cost.
See A§ 1026
D. Assume same realities such as section C over, apart from think the prepaid membership issuer also charges a lot charge of $1.25 whenever resources is transferred or packed from another asset profile, particularly from in initial deposit membership via a debit cards, throughout a deal on prepaid records without a sealed individual credit score rating ability, in addition to charging a $0.50 per transaction fee. The $1.25 excess in part C still is a finance charge because burden or transfer costs that are charged from the advantage ability of prepaid take into account credit score rating through the covered different credit score rating element become compared and then each transaction fees imposed for accessing funds inside the house feature associated with prepaid take into account prepaid profile without these a credit function. Per deal fees for a transaction that will be carried out to load or suck resources into a prepaid accounts from some other origin are not equivalent for reason for A§ 1026.4(b)(11)(ii).