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.
| Penalty APR | 23.99% |
|---|---|
| Late payment fee | up to $40 |
| Foreign transaction fee | 1% |
| Cash advance fee | Either $10 or 5% of the amount of each |
| Balance transfer fee | Either $10 or 5% of the amount of each |
| Grace period | 25 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.
Applications are handled by Commerce Bank, not by us. We do not take applications and cannot say whether you would be approved.
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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.