Agreements as filed with the CFPB. Not an offer of credit. How we read them
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Commerce Bank

ip commerce premier fcl

What this agreement does and does not disclose, and why that gap matters when you are comparing what a card costs.

Before you read the numbers.

This agreement prices the card as the Prime Rate plus a margin rather than as a fixed APR. The figure shown is that margin in percentage points, not an APR. The rate actually charged moves whenever Prime moves, so the cost of carrying a balance changes without the issuer amending the agreement.

Disclosed rates and fees

Every figure below was read from this issuer's filed agreement. Anything the filing does not state is left out of this table rather than shown as zero.

Terms as disclosed in the filed agreement for ip commerce premier fcl
Penalty APR23.99%
Late payment feeup to $40
Foreign transaction fee1%
Cash advance feeEither $10 or 5% of the amount of each
Balance transfer feeEither $10 or 5% of the amount of each
Grace period25 days
Minimum interest charge$2.5

Analysis

The ip commerce premier fcl filing quotes margins over Prime instead of finished rates. What that leaves knowable — and what it does not — is the subject of this analysis.

What this filing discloses

What follows is drawn entirely from Commerce Bank's CFPB filing for ip commerce premier fcl. The filing runs one page.

On the record here: a penalty rate, a late payment maximum, a foreign transaction fee and a grace period. It is silent on a purchase rate, a cash advance rate and a balance transfer rate.

Confidence in the parse of this filing is moderate rather than high, so the figures below are best checked against the original.

Priced off the Prime Rate

What this agreement discloses is a set of margins added to the Prime Rate. Until Prime is supplied, none of these figures is an APR, and this page will not treat them as one.

As read from the document: 23.99 points for penalty pricing.

The practical consequence is that this card has no single disclosed price. The cost of carrying a balance moves whenever the Prime Rate moves, in lockstep and without notice, and no arithmetic on this page can tell you what it costs today.

Confidence in the parse of this filing is moderate rather than high, so the figures below are best checked against the original.

The no-interest path

25 days is the disclosed grace period for purchases — the interval in which paying in full costs nothing.

The $2.50 minimum interest charge means the effective cost of carrying a very small balance is far higher than the quoted APR implies.

When a payment is late

The maximum late fee is $40 — roughly the 72nd percentile of the late fee ceilings disclosed across this index.

What the card costs before you borrow

For cash advances the filing discloses a cash advance fee of $10 or 5% of the advance, whichever is greater. The two halves of that fee cross at about $200: below it the flat $10 applies, above it the percentage does.

Transfers are charged $10 or 5% of the amount transferred, whichever is greater, though no distinct transfer APR appears in the document. Shifting $1,000 across attracts something like $50 in fees on day one.

Foreign transactions attract 1%. On $1,000 of overseas spending that is $10, charged on top of whatever exchange rate applies.

How it sits in the issuer's own range

165 separate Commerce Bank filings appear in the corpus.

What is outside the disclosure

This page cannot tell you a purchase rate and an annual fee, because the filing's disclosure table as read does not contain them.

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.

Go to the source

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

In short

What can be said is how this card is priced, not what it costs. That distinction is the whole of the analysis here, and the agreement is the place to confirm the index it uses.

The source document

This page is a reading of one document: the cardholder agreement Commerce Bank filed with the Consumer Financial Protection Bureau. Where the two disagree, the filing is correct and this page is wrong.

Open the filed agreement (PDF)

Applications are handled by Commerce Bank, not by us. We do not take applications and cannot say whether you would be approved.

Go to Commerce Bank

Other cards from Commerce Bank

All 165 agreements from Commerce Bank

Where this card sits

Groups this agreement qualifies for, by its own disclosed terms:

Comparable cards from other issuers

Closest disclosed margin over Prime among cards in the same groups.