In 2017, the predatory lending unit took aim at an open-end credit
plan lender, Allied Title, doing business at 23 offices as "Allied Cash Advance." In a civil lawsuit, state lawyers accused the company of making illegal, unlicensed loans at 273.75 percent annual interest.
On July 22, 2015, the Department amended its MLA regulation, primarily for the purpose of extending the protections of the MLA to a broader range of closed-end and open-end credit
products (the July 2015 Final Rule).
It is also beginning a review of "other potentially high-risk loan products and practices" such as open-end credit
In the case of consumer loans, banks generally follow a uniform charge-off policy set by the banks' regulators: open-end credit
(such as a home equity line of credit) is written off at 180 days delinquency, and closed-end credit (such as an auto loan) is written off at 120 days delinquency.
closed-end extension of credit that does not meet the definition of open-end credit
as an open-end plan.
Oklahoma--Oklahoma's Consumer Credit Code (Title 14A, Section 2-211) says that "no seller in any sales transaction may impose a surcharge on a cardholder who elects an open-end credit
card or debit card account instead of paying by cash, check or similar means"
The plan as a whole, including all its sub-accounts, is designed to be treated as open-end credit
22, 2010, implement parts of the Credit CARD Act passed last May, but don't read too much into that title: Certain advertising provisions in the rule affect all types of consumer open-end credit
plans, not just credit cards.
considered to be finance charges, be disclosed for open-end credit
The amendments principally deal with open-end credit
accounts and require new disclosures on periodic statements and on credit card applications and solicitations.
In part one of this series (September 2004), we reviewed open-end credit
and direct closed end credit.
[NEW!] Finally, to prevent creditors from evading HOEPA requirements, which cover only closed-end loans, creditors are prohibited from wrongfully structuring a home-secured loan as an open-end credit