Midas® Credit Card Current Credit Card Agreements

The Midas® Credit Card Current Credit Card Agreements filing from Comenity Capital Bank sets out a 35.99% purchase APR, a $35.88 annual fee and a 39.99% penalty rate. Against the 4,587 filings on this site, that rate lands around the 97th percentile.

On the face of the filing

Comenity Capital Bank submitted the terms for Midas® Credit Card Current Credit Card Agreements to the CFPB's agreement database; this is what they contain. The filing runs 12 pages.

Terms captured from the document include a purchase rate, a penalty rate, an annual fee line and a late payment maximum. A cash advance rate, a balance transfer rate and a foreign transaction fee are not stated.

Where the purchase APR sits

The purchase APR of 35.99% places this agreement around the 97th percentile of the set — it is about as high as anything filed here.

The arithmetic of revolving

Put $5,000 on the card and never reduce it, and twelve months of interest at the disclosed purchase rate comes to approximately $2,165.

The median purchase rate across the corpus is 21.99%; the same balance there would cost about $1,229. The gap — roughly $935 a year on $5,000 — is the price of this particular filing over a typical one.

These figures are arithmetic on the disclosed rate, not a quote: they assume the balance is never reduced, ignore any payments, and take no account of fees charged separately.

The no-interest path

The $3 minimum interest charge means the effective cost of carrying a very small balance is far higher than the quoted APR implies.

What a missed payment costs

A penalty APR of 39.99% sits in this filing, applied when the account falls into default as the agreement defines it. Against the 794 filings here that disclose one, that is roughly the 86th percentile.

Measured in money, moving from 35.99% to 39.99% costs an extra $117 or so annually on $2,000 — a far larger number than any single late fee.

Late payments are capped at $41 under this filing, about the 89th percentile of late fee maximums in the corpus.

Where the fees are

$35.88 a year is the disclosed annual fee, which ranks near the 84th percentile of the fees filed across this corpus.

One way to size that fee: at the card's own purchase rate of 35.99%, $35.88 is roughly the interest a balance of about $100 would generate in a year. The fee is a fixed cost that behaves like perpetual interest on that much debt.

Inside Comenity Capital Bank's filed lineup

100 separate Comenity Capital Bank filings appear in the corpus. The issuer's own range is 14.74%–35.99%. At 35.99%, this agreement is dearer than 47 of its siblings.

Its $35.88 annual fee is higher than 53 of the 89 sibling filings that state one.

What the filing does not tell you

The disclosure parsed here does not state anything about cash advances, balance transfer terms, a foreign transaction fee and a grace period. Those gaps are gaps in what could be read from the filing, and the PDF may well address them in prose the rate table does not capture.

More broadly, a CFPB agreement filing is a legal and pricing document. It does not describe rewards, benefits, sign-up offers, eligibility or approval criteria, and nothing of that kind has been inferred on this page. Where a card has features of that sort, they live outside this document entirely.

The document itself

The filed PDF is linked from this page and runs 12 pages. It is the authority for every figure summarised above; where this page and the document disagree, the document is right.

In short

This is an expensive agreement by the standards of the corpus, driven by a 35.99% purchase rate that is inert for a transactor and punishing for a revolver. Note that the $35.88 annual fee falls due whether the card is used or not.