Change-in-Terms & Cardholder-Agreement Review

Notice and Account Summary

The identifying spine of the review - the account/program identifier, document type, change categories, notice and effective dates, delivery method, and confirmation the plan is an open-end (not home-secured) credit card account - so a reviewer can orient before the analysis.

Change Summary

A fixed summary of the specific terms the notice changes - purchase / cash-advance / balance-transfer / penalty APRs, minimum-payment terms, the fee schedule, grace period, and balance-computation method - captured as prior-to-new where the prior value is shown (12 CFR 1026.6(b)(2), 1026.9(c)(2)).

Notice Type and Advance-Notice Requirement

The threshold determination - whether the notice is a significant change in terms (1026.9(c)(2)), a penalty / delinquency rate increase (1026.9(g)), or an account-opening disclosure, and whether 45-day advance notice is required or exempt under a 1026.9(c)(2)(v) carve-out.

Advance Notice Timing (45-Day Rule)

The core timing test - calendar days from notice to effective date and whether the 45-day advance-notice window is met (1026.9(c)(2)(i)(A) for a term change, 1026.9(g)(1) for a penalty rate increase), or Not applicable where advance notice is not required.

Right to Reject Assessment

Whether the change is subject to the consumer's right to reject and whether the notice discloses it and the post-rejection protections (1026.9(h), 1026.9(c)(2)(iv)(B)), including the 60-day-delinquency exception.

Rate Increase Justification and Re-Evaluation

For a rate increase, whether the reason is disclosed (1026.9(g)(3)(i)), whether the increase fits a CARD Act exception (1026.55), and whether it triggers the six-month reevaluation obligation (1026.59) or its delinquency carve-out.

APR, Fee, and Grace-Period Disclosures

An inventory of the required rate, fee, grace-period, and balance-computation disclosures (1026.6(b)(2)) with the disclosed value for each, one row per item, so a reviewer can see completeness at a glance.

Required Disclosure Checklist

The required-content checklist - one row per required element of the notice type (1026.9(c)(2)(iv) for a term change, 1026.9(g)(3) for a penalty increase, 1026.6(b) for an agreement) marked Present, Missing, Partial, or Not applicable with the cited subsection and location.

Disclosure Consistency Check

The notice reconciled against the institution's required-disclosure master template (or, absent one, its own internal consistency), one row per disclosure marked Match / Mismatch / Not found with discrepancy notes, treating placeholder number-fills and approved variants as matches.

Compliance Determination

The single overall disposition for the notice - compliant, or the specific violation type (timing, missing disclosure, right-to-reject, rate-increase justification/reevaluation, template inconsistency, multiple, or incomplete).

Compliance Exceptions Log

The exception log - one row per timing miss, missing or deficient disclosure, right-to-reject gap, unjustified rate increase, or template inconsistency, each with the cited rule, a severity, the detail, and a concrete corrective action.