1 AN EMPIRICAL ANALYSIS OF RETAIL REVOLVING CREDIT A Research Study By E. Ray McAlister, Ph.D. North Texas State University Denton, Texas With the Assistance of Edward DeSpain Southern Methodist University Dallas, Texas Copyright @ 1975 by Credit Research Center Krannert Graduate School of Industrial Administration Purdue University West Lafayette, Indiana 47907 2 TABLE OF CONTENTS Page 4 LIST OF TABLES Chapter 1. SUMMARY AND MAJOR READINGS Legislative Background Origin and Design of the Study Major Characteristics of Account Usage Impact of Method of Assessing Finance Charges What is a Fair Method of Assessing Finance Charges? Customer Awareness and Understanding of Rates of Charge Recommendations 11 11 11 13 14 14 16 17 2. LEGISLATIVE HISTORY Retail Installment Sales Acts Uniform Consumer Credit Code Federal Legislation Revolving Credit Legislation 19 20 20 20 21 3. ORIGIN AND DESIGN OF THE STUDY Need for This Study Major Objectives of the Analysis Definitions Relationships Between Billing Methods Sample Design Methodology 28 28 28 29 32 34 35 4. REVOLVING CREDIT—CHARACTERISTICS OF ACCOUNT USE Summary of Major Characteristics Size of Balance and Volume of Purchases Size of balance in Relation to Household Income and Education Volume of Purchase Activity Credit Card Use by Income Dollar Finance Charges Incurred Rates of Finance Charge Paid Effect of Lower Rates of Finance Charge Effect of $.50 Minimum Charges on Customer Cost 39 39 40 41 42 44 44 50 53 55 5. IMPACT OF THE METHOD OF ASSESSING FINANCE CHARGES Average Differences in Finance Charges Detailed Analysis of Monthly Differences in Dollar Finance Charges Impact of Method of Assessing Finance Charges on Yield to the Creditor Problems Resulting from Legislative Control Over Assessment Method Significant Features: A Summary 60 60 62 95 98 99 3 6. CUSTOMER AWARENESS OF RATES OF CHARGE AND OTHER ASPECTS OF ACCOUNT USAGE Awareness of Rates of Charge Customer Knowledge of the Dollar Cost of Revolving Credit at 18% Annual Percentage Rate Customer Opinions Regarding Fairness of Rate of Charge Customer Opinion as to What a Fair Dollar Finance Charge Would Be Major Problems in Customer Awareness Attitudes Toward Changes in Billing Practices Billing Errors as Reported by Respondents 102 109 113 116 116 119 APPENDIX A 122 APPENDIX B 125 101 101 LIST OF TABLES Table 2-1 Page State Legislation Specifically Covering Retail Installment Sales, by Scope of Of Coverage, January, 1975 22 Comparison of Certain Characteristics of the Original Sample of 865 Accounts with the 550 Respondents to the Demographic Questionnaire 37 Empirical data Concerning Sears Revolving Charge Account Usage in Texas, Selected Summary Statistics, 865 Accounts 40 4-2 Average Monthly Unpaid Balances, Previous Balance Method (865 Accounts) 41 4-3 Average Monthly Account Balance by Income Group 42 4-4 Average Monthly Account Balance by Education group 43 4-5 Total Dollar Sales Volume by Income Group 43 4-6 Total Dollar Sales Volume by Education Group 44 4-7 Credit Card Use by Income 45 4-8 Average Monthly Dollar Finance Charges Incurred, Previous Balance Method (865 Accounts) 45 Selected Characteristics of Revolving Charge Account Usage Based on Frequency of Finance Charge Assessment 47 4-10 Assessment of Finance Charges by Household Income Groups 48 4-11 Impact of Finance Charge Assessment by Income Groups 49 3-1 4-1 4-9 4 4-12 Assessment of Finance Charges by Education Level 50 4-13 Impact of Finance Charge Assessment by Education Level 51 4-14 Annual Percentage Rate Paid by 865 Accounts 52 4-15 Number of Times that a $.50 Minimum Finance Charge was Imposed 57 4-16 Payment of $.50 Minimum Charges by Income Groups 57 4-17 Frequency of Payment of $.50 Minimum Charges by Income Group 58 4-18 Payment of $.50 Minimum Charges by Education Level 59 4-19 Frequency of Payment of $.50 Minimum Finance Charge by Education Level 59 5-1 Average Monthly Dollar Finance Charges Under Six Different Billing Methods, 865 Accounts 61 Differences in Average Monthly Dollar Finance Charges, Six Billing Methods, 865 Accounts (Based on Median Figures) 61 Differences in Average Monthly Dollar Finance Charges, Six Billing Methods, 865 Accounts (Based on Median Figures) 62 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Adjusted Balance (Original Sample as Compared To Demographic Survey) 63 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Adjusted Balance by Household Income Groups 65 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Adjusted Balance (Share of Total Dollar Difference by Income Groups) 66 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Adjusted Balance by Education Level 67 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Adjusted Balance (Share Total Dollar Difference by Education Level) 68 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Adjusted Balance Including Debits (ADBW) (Original Sample as Compared to Demographic Survey) 69 5-2 5-3 5-4 5-5 5-6 5-7 5-8 5-9 5 5-10 5-11 5-12 5-13 5-14 5-15 5-16 5-17 5-18 5-19 5-20 5-21 5-22 Relative Impact on Customer Finance Charges Under Previous Balance as Compared to Average Daily Balance Including Debits (ADBW) by Income Group 70 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Adjusted Balance Including Debits (ADBW) by Household Income Groups 71 Average Monthly Difference in Dollar Finance Charges, Where Previous Balance Exceeded Average Daily Balance Including Debits (ADBW) (175 Accounts)— Share of Total Dollar Difference by Income Group 72 Average Monthly Difference in Dollar Finance Charges, Where Average Daily Balance Including Debits (ADBW) Exceeded Previous Balance (148 Accounts)— Share of Total Dollar Differences by Income Groups 72 Relative Impact on Customer Finance Charges Under Previous Balance Compared to Average Daily Balance Including Debits (ADBW) by Education group 73 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Average Daily Balance Including Debits (ADBW) by Level of Education 75 Average Monthly Difference in Dollar Finance Charges, Where Previous Balance Exceeded Average Daily Balance Including Debits (ADBW) (175 Accounts)— Share of Total Dollar Difference by Education Level 75 Average Monthly Difference in Dollar Finance Charges, Where Average Daily Balance Including Debits (ADBW) Exceeding Previous Balance (148 Accounts)— Share of Total Dollar Difference by Education Level 76 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Average Daily Balance Excluding Debits (ADBX) (Original Sample As Compared to Demographic Survey) 77 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Average Daily balance Excluding Debits (ADBX) by Household Income Groups 78 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Average Daily Balance Excluding Debits (ADBX)—Share of Total Dollar Difference by Income Groups 78 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Average Daily Balance Excluding Debits (ADBX) by Education Level 80 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to Average Daily Balance Excluding Debits (ADBX)—Share of Total Dollar Difference by Education Level 80 6 5-23 5-24 5-25 5-26 5-27 5-28 5-29 5-30 5-31 5-32 5-33 5-34 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to True Actuarial Average Daily Balance (TADB) (Original Sample as Compared to Demographic Survey) 82 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to True Actuarial Average Daily Balance (TADB) by Household Income Group 83 Average Monthly Differences in Dollar Finance Charges, Where True Actuarial Daily Balance (TADB) Exceeds Previous Balance (483 Accounts)—Share of Total dollar Difference by Income Group 84 Differences in Average Monthly Dollar Finance Charges, Previous Balance as Compared to True Actuarial Average Daily Balance (TADB) by Education Level 85 Average Monthly Differences in Dollar Finance Charges, Where True Actuarial Daily Balance (TADB) Exceeds Previous Balance (483 Accounts)—Share of Total dollar Difference by Education Level 85 Differences in Average Monthly Dollar Finance Charges, Average Daily Balance Including Debits (ADBW) as Compared to Average Daily Balance Excluding Debits (ADBX) (Original Sample as Compared to Demographic Survey) 86 Differences in Average Monthly Dollar Finance Charges, Average Daily Balance Including Debits (ADBW) as Compared to Average Daily Balance Excluding Debits (ADBX) by Household Income Group 87 Average Monthly Differences in Dollar Finance Charges, Average Daily Balance Including Debits (ADBW) as Compared to Average Daily Balance Excluding Debits (ADBX)—Share of Total Dollar Difference by Income Group 87 Differences in Average Monthly Dollar Finance Charges, Average Daily Balance Including Debits (ADBW) as Compared to Average Daily Balance Excluding Debits (ADBX) by Education Level 88 Monthly Differences in Dollar Finance Charges, Average Daily Balance Including Debits (ADBW) as Compared to Average Daily Balance Excluding Debits (ADBX)—Share of Total Dollar Difference by Education Level 89 Differences in Average Monthly Dollar Finance Charges, Adjusted Balance as Compared to Average Daily Balance Including Debits (ADBW) (Original Sample As Compared to Demographic Survey) 89 Differences in Average Monthly Dollar Finance Charges, Adjusted Balance as Compared to Average Daily Balance Including Debits (ADBW) by Household Income Group 90 7 5-35 Differences in Average Monthly Dollar Finance Charges, Adjusted Balance as Compared to Average Daily Balance Including Debits (ADBW)—Share of Total Dollar Difference by Income Groups 91 Differences in Average Monthly Dollar Finance Charges, Adjusted Balance as Compared to Average Daily Balance Including Debits (ADBW) by Education Level 92 Differences in Average Monthly Dollar Finance Charges, Adjusted Balance as Compared to Average Daily Balance Including Debits (ADBW)—Share of Total Dollar Difference by Education Level 92 Differences in Average Monthly Dollar Finance Charges, Adjusted Balance as Compared to Average Daily Balance Excluding Debits (ADBX)— Original Sample as Compared to Demographic Survey 93 Differences in Average Monthly Dollar Finance Charges, Adjusted Balance as Compared to Average Daily Balance Excluding Debits (ADBX) by Household Income Group 94 Differences in Average Monthly Dollar Finance Charges, Adjusted Balance as Compared to Average Daily Balance Excluding Debits (ADBX)—Share of Total Dollar Difference by Income Group 94 Differences in Average Monthly Dollar Finance Charges, Adjusted Balance as Compared to Average Daily Balance Excluding Debits (ADBX) by Education Level 96 Differences in Average Monthly Dollar Finance Charges, Adjusted Balance as Compared to Average Daily Balance Excluding Debits (ADBX)—Share of Total Dollar Difference by Education Level 96 Total Dollar Finance Charge Revenue and Annual Yield Under Six Different Billing Methods 97 Knowledge of Annual Percentage Rate of Charge as Related to Household Income and Education 103 6-2 Knowledge of Annual Percentage Rate as Related to Finance Charge Assessment 103 6-3 Opinion as to Dollar Finance Charge on Revolving Account at 18% as Related To Household Income and Education 105 An Illustration of the Total Finance Charge Revenue and Annual Percentage Rate on a Revolving Account at a Monthly Charge of 1 ½%, Previous Balance Method 106 An Illustration of the Total Finance Charge Revenue and Annual Percentage Rate on a Revolving Account at a Monthly Charge of 1 ½%, Average Daily Balance 107 5-36 5-37 5-38 5-39 5-40 5-41 5-42 5-43 6-1 6-4 6-5 8 6-6 An Illustration of the Total Finance Charge Revenue and Annual Percentage Rate on a Revolving Account at a Monthly Charge of 1 ½%, Adjusted Balance Method 108 Opinion as to Dollar Finance Charge on Revolving Account at 18% as Related to Knowledge of Annual Percentage Rate 108 Opinion as to Dollar Finance Charge on Revolving Account at 18% as Related to Finance Charges Actually Incurred 109 Opinion as to Fairness of Finance Charges Assessed as Related to Household Income and Education 110 Opinion Regarding Fairness of Finance Charge Assessed as Related to Knowledge of Annual Percentage Rate 111 Opinion as to Fairness of Finance Charges Assessed as Related to Annual Finance Charges Actually Incurred 111 Opinion as to Fairness of Finance Charges Assessed as Related to Average Number of Months in Which Finance Charges Were Incurred 112 Opinion as to Fairness of Finance Charges Assessed as Related to Customer Estimate Of Dollar Finance Charge on Revolving Account at 18% 112 Opinion as to What Dollar Finance Charge to Finance $100 for One Year Would Be Fair as Related to Customer’s Opinion Regarding Fairness of Finance Charge Assessed 113 Opinion as to What Dollar Finance Charge to Finance $100 for One Year Would be Fair as Related to Household Income and Education 115 Opinion as to What Dollar Finance Charge to Finance $100 for One Year Would Be Fair as Related to Customer Estimate of Dollar Finance Charge on Revolving Account at 18% 115 6-17 Types of Billing Practice Changes Desired 117 6-18 Opinion Regarding Changes in Billing Practices 118 6-19 Opinion Regarding Desired Changes in Billing Practices as Related to Household Income and Education 119 Opinion as to Need for Billing Practice Changes as Related to Number of Store Cards Held 120 Billing Error Experience in Relation to Number of Department Store Credit Cards Held 120 Billing Error Experience in Relation to Household Income and Education 121 6-7 6-8 6-9 6-10 6-11 6-12 6-13 6-14 6-15 6-16 6-20 6-21 6-22 9 ACKNOWLEDGEMENTS A study of this type would not have been possible without the willingness of a creditor to open its account records to independent analysis. The Management of Sears, Roebuck and Company were willing to do this, and not at an inconsiderable expense. For this, they are to be commended. A major contribution to this study was made by Dr. James F. Smith, Director of Econometric Research for Sears in Chicago. It was he who first realized the potential value of the project when it was proposed to him in the fall of 197 1. He was instrumental in securing its approval, and provided continuous assistance in many ways throughout its course. Official approval and the necessary funds were granted by Corporate Vice President for Credit, Linden E. Wheeler. Administrative support was provided by Alfred I. Davies, Vice President of the Southwestern Territory, by Harold Robinson, Territorial Credit Manager, and by Alan Griswood, General Attorney for the Southwestern Territory. H.R. Lively and George Braasch, both of the corporate offices, were helpful in many ways. A special word of thanks is deserved by J.R. Peek, Data Processing Coordinator for the Southwestern Territory. Without his able and willing assistance and patience, selection of the sample and collection of account data on which the study was based would not have been possible. Many other individuals provided assistance in various ways, but a special mention is warranted of the services provided by Wanda Hood. She patiently typed all of the tables and the text. This project would not have been possible without the invaluable assistance of Edward DeSpain of Southern Methodist University. The basic computer program on which the entire study was based was his original creation. In addition, he supplied much valuable advice and editorial assistance. When this study was begun in the fall of 1971, it was on a no-budget basis. It was a part-time effort for more than a year. A special note of appreciation is due Sears, Roebuck and Company for the grant of research funds to North Texas State University which allowed full-time attention to this project for the last year until completion. E. Ray McAlister 10 CHAPTER 1 SUMMARY AND MAJOR FINDINGS Consumer revolving credit is a rapidly-growing phenomenon. Its increased use has been accompanied by a growing debate over certain of its aspects. Much legislation and litigation has dealt with problems concerning methods of finance charge assessment, application of usury laws, and determination of a fair and equitable rate of finance charge. LEGISLATIVE BACKGROUND Most states have enacted legislation pertaining directly to retail installment sales, including revolving credit. Ordinarily, these statutes provide for contract disclosure of key items of information and for limits on permissible finance charges. Other significant legislation pertaining to revolving credit includes the Uniform Consumer Credit Code (now adopted in seven states) and the federal Truth in Lending Act. Most recently, legislative attention has been directed to the method of finance charge assessment, correction of billing errors, and other similar aspects of billing practices. Ten states have adopted legislation specifically authorizing the use of certain methods of finance charge assessment.1 All have the effect of outlawing use of the Previous Balance system (that is, where finance charges are based on the beginning monthly balance without deducting current month's payments and before adding current month's purchases). Attempts have been made at the federal level to accomplish the same objective. On the litigative front, efforts have been made to apply usury laws to revolving credit sales and to outlaw use of the Previous Balance system through judicial interpretation of existing statutes. With the exception of jurisdictions in Iowa, South Dakota, and Wisconsin, the courts have ruled consistently that the "time price doctrine" applies to revolving credit sales and that finance charges on such sales are not "interest" under usury statutes. Cases challenging use of the Previous Balance system had been unsuccessful in every instance (New York, Florida, and California) until a 1974 trial court decision in Michigan (see Chapter 2). ORIGIN AND DESIGN OF THE STUDY Because of the growing concern about retail revolving credit by courts and legislatures, existence of empirical research data would aid decision making by these bodies. Much of the legal activity mentioned has occurred without the benefit of actual data, however, and reliance has been placed almost entirely upon hypothetical conjectures and artificial paradigms. This study was designed to accomplish three major purposes: (1) to collect and analyze actual usage data from a randomly selected sample of accounts over a 12-month period, (2)to simulate and measure the impact of method of finance charge assessment on customer costs and other account use characteristics, and (3) to collect and relate to account use certain demographic data (e.g., incomes, education) and to cost differences resulting from changes in method of assessment. Sample Design The first step required in this study was the selection of a representative sample of actual accounts held by customers of Sears, Roebuck and Company in Texas from over 600,000total in the state. Use of a single billing 1 Arizona, Colorado, Iowa, Maine, Maryland, Massachusetts, Minnesota, Montana, Virginia, West Virginia, and District of Columbia. 11 cycle was deemed appropriate since customers were assigned to cycles in a completely random manner and since preparation of a computer program for analysis of the data would be greatly simplified by using this method of selection. Thus, the sixth billing cycle, closing on the 12th of the month, was chosen randomly. After determining the first unit of the sample to be chosen by use of a table of random numbers, every fortieth account was selected from a list of active accounts as of December 12, 1971, provided that the account met the necessary parameters. Accounts excluded from the sample included any with one or more of the following characteristics: 1 . Accounts with less than a full year's activity. It was not necessary that the account have actual activity (that is, purchase or payment) during each of the 12 months studied, but it had to be open and subject to use by a resident of Texas. 2. Accounts of customers who were not residents of Texas. 3. Accounts which, at any time during the 1 2-month period of study, were more than one month delinquent in payment. The decision to exclude "extreme past due" accounts was based on the desire to know what costs and rates were involved when accounts were paid according to the agreement signed by the customer. Otherwise, it would not have been possible to evaluate the significance of the terms on the original agreement as they affect the buyer. 4. Employee accounts were not included because of a difference in the treatment of finance charge assessment. This procedure produced account histories for a 1 2-month period for a total of 865 accounts. These records came from all parts of the state-every town in which Sears had a "retail" store (although some towns with "mailorder" outlets only were not included). Data used in the study were copied manually from original records on a month-to-month basis. All transactions on the account during the 12 months were recorded, including the dates involved. A computer program for analysis of the data was prepared by Mr. Edward DeSpain of Southern Methodist University in Dallas, Texas. Assessment Method Examined The method of assessing finance charges in use on the accounts selected for study was the Previous Balance system. Finance charges were assessed on these accounts at the following rates: (1) $.50 on balances from $1 to $33.33, (2) 1.5% per month on balances from $33.33 to $500, and (3) 1 % per month on that part of an unpaid balance in excess of $500. Five other methods of assessing finance charges on revolving accounts were simulated as follows (see Chapter 3 for complete description): 1 . Adjusted Balance (beginning balance less payments and credits). 2. Ending Balance (balance owed at the end of each billing cycle). 3. Average Daily Balance Including Debits (sum of daily balances divided by number of days in the billing period). 12 4. Average Daily Balance Excluding Debits (sum of daily balances excluding current month's purchases divided by number of days in the billing period). 5. True Actuarial Average Daily Balance (same as number 3 above except charges are also levied for any month in which there is activity on an account even if the account is paid in full that month). MAJOR CHARACTERISTICS OFACCOUNT USAGE Analyses of actual account data over an extended period provided excellent examples of "typical" account usage. Average account balances were considerably less than often imagined ($91.90). Average finance charges incurred amounted to $1.24 a month ($14.88 yearly). One-half of the customers had average monthly account balances of $37.27 or less and incurred average finance charges of no more than $.31 a month ($3.72 a year). Charges were incurred at a mean annual percentage rate of 11.64% despite the fact that finance charges were assessed at a "nominal" annual percentage rate of 18%. Customers displayed three distinct patterns of account usage: (1) those who never paid a finance charge during the 12-month period because of payment of account balances in full upon receipt of statement (26% of the total sample), (2) those paying finance charges every month during the year (25% of the sample), and (3) those who incurred finance charges during some months but not in others (49% of the sample). Two simulations were made to measure the impact of certain changes in the rate structure on revolving accounts. The first, which levied charges at a 1 % monthly rate on all balances, produced an average monthly finance charge of $.84, indicating a savings of $.40 a month (less than $5 yearly)for an average customer. The other eliminated $.50 minimum monthly charges on account balances under $33.33 (that is, apply a straight 1.5% monthly rate). This produced an average monthly finance charge of $1.23, a savings of $.01 per month for an average customer. It was further determined that no minimum charge was assessed on 73% of the accounts and that in no instance did the number of minimum charges incurred by any customer exceed nine over the period studied. For the customer who paid a $.50 minimum nine times during year, omission of the charge would have produced a savings of $.87 over the 12 months. Account Usage Related to Income and Education It has often been alleged that certain income and educational levels feel the impact of finance charges more heavily than others. The following findings are appropriate to this allegation: 1 . There is no clear pattern relating household income or education to the size of account balance maintained. 2. Income and education are related directly to the likelihood of having a Sears Revolving Charge Account, to the frequency of its usage, and to the average dollar amount purchased per month. 3. Concerning the total dollar impact of finance charges assessed, lower and middle income groups ($20,000 and under) are affected somewhat more than higher-income families. There is no clear pattern relating education to the amount of finance charges assessed. 4. Minimum finance charges are incurred more frequently by low income families, but the overall dollar impact is insignificant regardless of income level. No family with an income below $10,000 incurred such charges more than four times during the year. 13 IMPACT OF METHOD OF ASSESSING FINANCE CHARGES It has been assumed by many that choice of billing method makes possible substantial differences in dollar amounts of finance charges paid by customers. Part of the problem involves defining "substantial," but a more significant question concerns the wisdom of using hypothetical examples instead of empirical data in predicting such cost differences. For the average customer in this study, monthly finance charges under various assessment methods would amount to the following, assuming the purchase and payment behavior remained unchanged: 1. Adjusted Balance ......................................................................$1.09 2. Average Daily Balance Excluding Debits ................................$1.18 3. Previous Balance ......................................................................$1.24 4. Average Daily Balance Including Debits .................................$1.24 5. Ending Balance ........................................................................$1.41 6. True Actuarial Average Daily Balance ....................................$1.47 It is noteworthy that the Previous Balance system (which has received the heaviest fire from critics)costs only $.15 a month more, on the average, than the Adjusted Balance method and only $.06 a month more than another widely used system, Average Daily Balance Excluding Debits. On the average, it produces the same level of charges as Average Daily Balance ,Including Debits, and lower charges than either Ending Balance or True Actuarial Average Daily Balance. Thus, empirical reality does not support the criticisms of the Previous Balance method which claim that much greater finance charges are to be expected from its use. Assessment Method Related to Income and Education It has been alleged that some billing methods, particularly the Previous Balance system, work to the disadvantage of poor and unsophisticated consumers. Comparisons of the cost differences resulting between seven possible combinations of billing methods seem to warrant three major conclusions: (1) Lower-income families ($7,500 or less)do not experience a greater than proportionate share of the dollar cost resulting from increased finance charges produced under certain assessment methods. In most cases, middle-income families ($10,000 to $20,000) absorb the largest share of the dollar differences; (2) Families with less educational attainment do not bear the dollar impact of cost differences to a greater extent than other educational levels; (3) A change in assessment method from a more expensive (i.e., Previous Balance) to a less expensive one (i.e., Adjusted Balance) generally produces smaller finance charges for a majority of customers, but the greatest relative gain from the change is experienced by families with incomes of between $10,000 and $20,000. Conversely, a change in billing method from a less expensive one to a more expensive one, while resulting in greater finance charges for a majority of customers, also produces the largest relative cost increase for middle-income families ($10,000 to $20,000). Overall, propositions which assert that poor and unsophisticated consumers are treated unfairly by certain assessment methods are unsupported by these empirical findings and are exaggerated at best. WHAT IS A FAIR METHOD OF ASSESSING FINANCE CHARGES? Frequently, attempts are made to describe certain methods of assessing finance charges as "fair" while others are condemned as "unfair." Admittedly, such a description is one of judgment, made particularly difficult by the fact that some standard of "fairness" must be employed in making it and disagreement exists as to the proper standard. 14 It may be appropriate to consider five possible aspects that might be used in some combination to determine the "fairness" of any particular billing method. For example, 1 . What is the actual yield under the billing method compared to the stated nominal annual percentage rate revealed on the contract as required under Truth in Lending? 2. Are purchases and payments treated alike? 3. Is there any discrimination against certain socioeconomic groups in the market? 4. What do consumers generally think is "fair"? 5. How does the actual yield compare to the costs of providing credit? Actual Yield Vs. Stated Rate Only one billing method-True Actuarial Average Daily Balance-produces a yield exactly equal to the stated nominal annual percentage rate. All other methods, on average, produce smaller gross yields than the stated rate. Three billing methods, Average Daily Balance Including Debits, Average Daily Balance Excluding Debits, and Adjusted Balance, always produce gross yields less than or equal to the stated rate. Previous Balance and Ending Balance theoretically can produce yields on a single account greater than the stated rate provided that customers do not take full advantage of the credit terms and pay earlier than necessary. If payments are made no earlier than absolutely necessary under the contract, then these two methods also will not produce yields greater than the stated rate. Empirical evidence indicates strongly that both Previous Balance and Ending Balance do not, on the average, produce yields greater than the stated nominal rate. Thus, for all methods assessing finance charges other than True Actuarial Average Daily Balance, the deviation from the stated nominal annual percentage rate is in favor of the consumer, not the creditor. Purchases Vs. Payments By this measure of fairness, four billing methods-True Actuarial Average Daily Balance, Average Daily Balance Including Debits, Previous Balance, and Ending Balance-treat purchases and payments within the billing cycle symmetrically. The remaining two methods-Adjusted Balance and Average Daily Balance Excluding Debits-give credit for customer payments but do not charge for current month's purchases. Effect on Socioeconomic Groups Under all methods of assessing finance charges, all customers are treated equally. Everyone operates under the same rules regarding treatment of purchases and payments. Empirical evidence gathered in this study indicates that there is no systematic discrimination under any billing method against any one combination of social or economic factors. Thus, by this standard, all methods are "fair" to those who have credit. However, the allowable rate and method of calculation determines who does and does not receive credit. Yield Vs. Cost By this standard one would need to compare finance charges paid to the cost of providing credit. More generally, the value of credit to the consumer (what he would be willing to pay, rather than what he paid) might be compared to the costs of credit services. The studies done to date suggest that firms break even at best, and also indicate that under many circumstances, the consumer would be willing to pay much more for the credit he 15 receives than he has to pay. Thus, by this standard, the consumer benefits. To mandate legislatively a billing method (i.e., Adjusted Balance or Average Daily Balance Excluding Debits) or a ceiling rate that is effective determines who will get credit arbitrarily, not leaving the choice to the consumer. What Consumers Think is Fair? When consumers are asked to identify the percentage rate of finance charge involved on revolving credit accounts, their answers do not indicate a very accurate knowledge. Likewise, when asked to identify the cost of revolving credit in dollars and cents, the tendency is to overstate actual costs. However, when asked to identify in dollars and cents what they consider to be a "fair" charge (without tying the response to what they actually think is being charged), the vast majority respond by citing a figure which varies little, if any, from the costs produced under current billing methods. Thus, if what consumers think is fair is used as the standard, all billing methods currently used by reputable retailers and bank card agencies would be "fair" as judged by a vast majority of all customers. CUSTOMER AWARENESS AND UNDERSTANDING OF RATES OF CHARGE Only one-third of the respondents were able to identify correctly the split rates of finance charge on their revolving account on amounts under $500 and on amounts over $500. Counting those who knew only the rate on the first $500 of a balance, 57% of the respondents were at least partially aware of the rates. Awareness of rate usually increased with greater incomes and educational levels. The frequency with which finance charges were incurred by respondents had no apparent effect on the level of rate awareness. Although at least partial awareness of the annual percentage rate of charge was reasonably good (over 50%), the ability to translate this rate into a correct dollar cost was woefully lacking among the respondents. When asked what the dollar cost of financing a $100 purchase on a revolving account over a 12-month period would be, over 90% overestimated the actual cost (about 40% said $18). An understanding of the rate in terms of equivalent dollar cost was slightly greater among higher income levels and educational groups, but the pattern was not consistent for all groups. Neither awareness of the correct annual percentage rate nor the frequency of finance charges incurred was related to knowledge of the equivalent dollar cost. A large majority of the respondents felt that the finance charges assessed were unfair. Opinions about the fairness of charges evidently were not related to the frequency of finance charges assessed. The respondent's estimate of the dollar cost did, however, affect his opinion of fairness. Those who were aware of the true dollar cost were more likely to feel that the charge was a fair one. When asked to give an opinion as to the amount of finance charge which would be considered fair for financing a revolving credit purchase of $100for a year, the most common answer ranged from $9 to $10 for a year. Under most assessment methods, the cost of revolving credit of $100 for a year would not exceed this range (see Chapter 6). From these findings, two conclusions seem warranted: (1) awareness of the annual percentage rate of charge is much greater than a correct understanding of the meaning of a given annual percentage in terms of equivalent dollar cost; (2) if customers were aware of the actual dollar cost of revolving credit as well as the annual percentage rate, their opinions as to fairness of such charges would probably be much more favorable. 16 Desired Billing Practice Changes In addition to determining customer awareness and understanding of rates of charge, certain questions were designed to obtain customer opinions regarding those billing practices which they would like to see changed. Over 70% of the respondents expressed no desired changes. The most desired change concerned excessive finance rates (21 respondents out of 550). Second in importance (17 each out of 550) were complaints about the Previous Balance method and about certain billing procedures, such as delays in mailing statements or posting payments. The evidence of this study revealed no broadly-based dissatisfaction with current billing practices. RECOMMENDATIONS Several recommendations result from the findings of this study. Some of these relate to policy decisions by creditors; others should be of value in legislative decision making. Creditor Policy Consideration of a change in assessment method should involve examination of four areas: (1) legal implications, particularly a growing concern over use of the Previous Balance method, (2) the effect on finance charge revenues to the store and costs to customers, (3) the effect on sales volume, and (4) general community image. The following recommendations are made with the above factors in mind: 1. Previous Balance and Adjusted Balance methods have the advantage of being easy to explain to customers and at the same time easy to administer. Either can be used with manual billing systems. 2. The Previous Balance method produces the greatest finance charge revenues of any other than the Average Daily Balance method that also allows use of the account on a 30-day charge basis with no finance charge, i.e., free time. 3. Previous Balance has an advantage of customer familiarity through longstanding customary use in the retail industry. 4. Legal complications and/or customer relations could produce a need to change from Previous Balance to an alternative system. 5. If a change becomes necessary, the transfer to Average Daily Balance Including Debits provides for approximately the same level of finance charge revenues while effectively eliminating the major complaint against the Previous Balance method (i.e., failure to give credit for payments before imposition of finance charges). 6. A change to Average Daily Balance Excluding Debits provides for approximately 5-6% less finance charge revenue but may offer a competitive advantage since current month's purchases are excluded from finance charge calculations (in contrast to Average Daily Balance Including Debits). 7. A change to Adjusted Balance produces severe reductions (12%) in total finance charge revenues leading possibly to a need for higher offsetting cash prices. 17 8. A change to True Actuarial Average Daily Balance produces the highest possible finance charge revenues per account but, undoubtedly, would reduce credit sales because of the loss of 30day charge account privileges, i.e., free time. 9. More emphasis should be placed on communicating the actual dollar cost of revolving credit over a period of time rather than relying solely on the annual percentage rate. Unfavorable opinions concerning the level of finance charges may originate from the tendency to overestimate the dollar cost produced by a given rate (i.e., 18% a year produces $18 per $100 per year). Legislative Implications The following judgments maybe of some interest to anyone concerned with the desirability of legislation affecting revolving credit: 1. Because cost differences under alternative methods of finance charge assessment have minimal dollar impact on an average customer, failure to mandate legislatively a specific billing method is not necessarily contrary to the best interest of consumers. 2. Specifications of any single billing method by statute is fraught with many difficult, if not insoluble, problems involving administration and equity to all parties involved. 3. The Adjusted Balance method, while usually producing lower finance charges, frequently results in very small savings to an average customer. These small savings can be offset by higher cash prices designed to recover the substantial loss of finance charge revenue to creditors who use this method. 4. Mandating an Average Daily Balance method, while eliminating complaints about the Previous Balance system, provides great difficulty for smaller retailers who are not computerized. The result could be forced discontinuation of in-house credit operations with substitution of bank charge plans or elimination of credit privileges. 5. Requiring a method of assessment which results in generally lower finance charge revenues produces a need to re-evaluate existing rate structures, since sharply lower revenues can produce higher cash prices or restriction of credit availability, both of which have greater impact on lower income groups. 6. Ideally, methods of finance charge assessment should be a matter of free choice by the creditor based on his competitive situation, financial condition, technical capabilities, and needs and desires of his customers. Customers who are provided full disclosure of the billing methods employed should be free to exercise their choice of credit plans to use. 18 CHAPTER 2 LEGISLATIVE HISTORY Depending upon one's point of view, growth in consumer installment debt over the past 30 years or so can be described as alarming, amazing, devastating, substantial but predictable, or any other of an infinite number of adjectives. By any standard, however, consumers have added large amounts to their installment debt. Since 1939, when consumers owed some $4 billion, the figure has risen to a sum approximately 36.5 times as large, or around $155 billion. In relation to disposable personal income, installment debt has grown from 5.7% of DPI in 1939 to 15.6% in 1974.1 Most of this growth has been a result of increases in disposable personal incomes, prices, and population.2 In spite of the fact that consumer debt has not expanded as rapidly in recent years (an average annual rate of increase of about 10% from 1960-1973 as compared to about 18% a year over the period from 1947 to 1956, or 121/2% during the decade 1950-1959), concern still exists with regard to possible economic effects of such growth and the abuses which become more numerous in absolute numbers as use of credit increases. One of the consequences of this substantial increase in the use of consumer credit has been an acceleration in attempts to enact legislation of various types designed to control questionable practices and prevent presumed harmful economic side effects from the overuse of credit. Consumer credit legislative activity since 1960 can easily be seen as overwhelming, even by those who regularly are involved either as practitioners or as students of the subject. Activity has centered primarily in the following areas: (1) Retail Installment Sales Act covering consumer credit sales of motor vehicles and other durable goods, (2) adoption of the Uniform Consumer Credit Code, a broad-based law designed to bring together all types of consumer credit statutes, (3) enactment of the federal Consumer Credit Protection Act(Truth in Lending Act) providing for regulations on disclosure and advertising of credit terms, and (4) legislation pertaining to revolving credit transactions (open-end credit). Only brief reference to the first three of these areas will be made since the principal concern of this study is revolving credit. RETAIL INSTALMENT SALES ACTS As illustrated in Table 2-1, since 1960 some eighteen states have enacted for the first time statutes specifically pertaining to retail installment sales. Many others passed laws substantially amending previously existing ones by expanding the scope of coverage to include goods and services other than motor vehicles and revolving credit transactions. As of January, 1975, all but one state (Arkansas) had adopted legislation pertaining specifically to some type of consumer installment credit (this figure includes seven states having adopted the Uniform Consumer Credit Code). In three states (Minnesota, Mississippi, and New Hampshire), statutes apply only to installment (closed-end) sales of motor vehicles and do not cover closed-end sales of other types of merchandise. Three 1 Board of Governors of the Federal Reserve System. Fed. Res. Bull., (April 1953), 354 and (November 1974), A47. For a more detailed examination of the growth on consumer credit and economic effects, see: Edgar Ray McAlister. Retail Installment Credit Growth and Legislation, Monograph No. 120. Columbus, Ohio: Bureau of Business Research, The Ohio State University, 1964, Chapter III; and Ray McAlister. "An Analysis of the Economic Impact of Consumer Installment Credit Since 1939," Business Studies, 1965, 5. 2 19 states (Arkansas, Hawaii, and New Hampshire) have no specific statutory provisions concerning retail revolving credit transactions. UNIFORM CONSUMER CREDIT CODE One of the most important consumer credit legislative developments of recent years was the adoption after years of extensive study of the Uniform Consumer Credit Code. Approval in 1968 by the National Conference of Commissioners on Uniform State Laws and the American Bar Association, it was later amended in 1969 and 1970. The Code is broad-based legislation designed to bring together all types of consumer credit legislation on a uniform basis. As of January, 1975 a total of seven states (Colorado, Idaho, Indiana, Kansas, Oklahoma, Utah, and Wyoming) had adopted it (see Table 2-1) with some variations from the model statute in all states except Utah. Presently, it is at various stages in the legislative process in many states. FEDERAL LEGISLATION In addition to the considerable state legislative activity during the sixties, landmark federal legislation was enacted in 1969 in the form of the Truth in Lending Act.3 The statute itself, along with Regulation Z (rules adopted by the Board of Governors of the Federal Reserve System to implement the law), and recent amendments to the basic statute (pertaining to credit reporting and the mailing of unsolicited credit cards), have opened up vast new areas of credit law. Most of the impact of the federal law has been in the area of contract disclosure and its regulations concerning advertising of credit terms. Unlike most state statutes, federal law does not limit finance charges. The most significant change came with the requirement to state finance charges in terms of an "annual percentage rate." With the exception of a very few states, before the Truth in Lending Act, legislative requirements were that finance charges be revealed in dollars and cents, not as a percentage rate. Substantial changes also were made in regard to the terminology that was to be used on credit contracts. Truth in Lending Act regulations concerning advertising of credit terms have probably had even more impact on business practices than have the disclosure requirements. Because of the federal statute, mention of almost any of the specific terms of a credit plan triggers the requirement to disclose almost all of the terms in the text of the advertisement. As a result, the debate among practitioners and enforcers of the law alike about the wisdom of the requirement has not yet subsided. In early 1973, the Federal Reserve Board proposed an amendment to Regulation Z, Secs.226.6and 226. 10 designed to encourage the advertising of specific terms for open-end credit and to harmonize the separate requirements for open-end and closed-end credit.4 In 1972 and 1973,therewas an attempt to amend the Truth in Lending Act by outlawing use of the Previous Balance method of calculating finance charges on open-end credit plans and by prohibiting use of minimum monthly charges on such accounts. These provisions were originally part of a proposed Fair Credit Billing Act sponsored by Senator William Proxmire of Wisconsin but were omitted from the final version of the bill reported out of committee.5 No doubt renewed attempts will be made in the future to eliminate these two practices and otherwise to regulate revolving credit transactions. 3 Truth in Lending Act (Title I of the federal Consumer Credit Protection Act), P.L. 90-321, 82 Stat. 146, T5 U.S.C. 1601. CCH Cons. Cred. Gd., Report No. 110, January 2, 1973, Pars. 3540, 3597, and 3598. 5 S. 652, 92d Cong., 2 Sess. 4 20 REVOLVING CREDIT LEGISLATION Legal issues surrounding revolving credit transactions generally have reference to the following: (1) applicability of usury statutes, (2) billing methods used, (3) rates of finance charge, including use of minimum monthly charges, and (4) certain other billing practices, such as the period of time within which statements should be mailed and within which payment can be made in order to avoid the imposition of a finance charge, and the procedures whereby errors in billing are to be corrected. Does Usury Apply? In the absence of legislation, retailers have traditionally relied on the "Time Price Doctrine" to support the addition of a finance charge to the cash price in a credit sale which would otherwise exceed the maximum interest rates generally limited by law. The "Time Price Doctrine" originated in England in 17746 and received recognition in this country by the United States Supreme Court in the case of Hogg v. Ruffner in 1861.7 Time Price Doctrine Under the "Time Price Doctrine," a seller is entitled to sell at one price for cash and a higher price for credit. Since the transaction is not a loan, the difference between cash price and credit price is not "interest" but a part of the credit price and, therefore, not subject to usury laws. The difference is sometimes referred to as a "time price differential," "service charge," or, as a result of the federal Truth in Lending Act, a "finance charge." (The federal Truth in Lending Act became effective in July of 1969 and requires meaningful disclosure of credit terms under a// forms of consumer credit extension including loans as well as sales; therefore, any charge imposed by a creditor as an incident to the extension of credit whether it be interest or time price differential must be uniformly disclosed as a "finance charge.")8 6 Floyer v. Edwards, 99 Eng. Rep. 995 (K.B. 1774). Hogg v. Ruffner, 66 U.S. 115, 17 L. Ed. 38 (1861). 8 Consumer Credit Protection Act, 15 U.S.C. 1601 et seq., esp. 102 and 106. 7 21 TABLE 2-1 STATE LEGISLATION SPECIFICALLY COVERING RETAIL INSTALMENT SALES, BY SCOPE OF COVERAGE January, 1975 State Date Motor vehicles Arkansas Alabama 1971 Alaska 1963 Arizona 1961, 1971 California 1945, 1962 Colorado* 1951, 1971 Connecticut 1947, 1972 Delaware 1960 District of Columbia 1960, 1971 Florida 1957, 1960 Georgia 1967 Hawaii 1962 Idaho* 1957, 1971 Illinois 1957, 1968 Indiana* 1935, 1971 Iowa 1957, 1974 Kansas* 1958, 1973 Kentucky 1956, 1963 Louisiana 1959, 1973 Maine 1958,1970,1974 Maryland 1941, 1967 Massachusetts 1959, 1966 Michigan 1939, 1967 Minnesota 1957, 1971 Mississippi 1958 Missouri 1961, 1963 Montana 1959 Nebraska 1959, 1965 Nevada 1953, 1965 New Hampshire 1961 New Jersey 1948, 1960 New Mexico 1959,1965 New York 1956, 1957 North Carolina 1972 North Dakota 1957 Ohio 1949 Oklahoma* 1969 Oregon 1958, 1963 a X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 22 Scope of coverage Other Revolving goods credit a X X X X X X X X X X X X X X X X X X X X X X a X X X X X a X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X TABLE 2-1 –Continued Scope of coverage State Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah* Vermont Virginia Washington West Virginia Wisconsin Wyoming* Date Motor vehicles 1947, 1967 1968, 1970 1968, 1974 1957, 1974 1961 1967 1953, 1969 1962, 1964 1950, 1973 1963, 1968 1968, 1974 1935, 1973 1971 X X X X X X X X X X X X X Other goods Revolving credit X X X X X X X X X X X X X X X X X X X X X X X X X a Usury state applies. * Has adopted Uniform Consumer Credit Code. Source: CCH Consumer Credit Guide and individual state statutes. In almost every state where the Time Price Doctrine has been considered, courts have held that a bonafide sale on time is not subject to the usury laws even though the time price differential exceeds maximum interest rates.9 In only two states, Arkansas and Nebraska, has the doctrine been rejected in application to retail installment sales (closed-end).10 It is noteworthy, however, that the Arkansas decision may have been compelled by a unique constitutional provision construed to limit all credit rates to 10%,11 while the Nebraska decision was nullified by a constitutional amendment and specific enabling legislation to allow revolving credit charges.12 Exceptions to Time Price Doctrine In 1965, the Time Price Doctrine was held by the Massachusetts Supreme Court to apply to revolving charge accounts. A similar decision was handed down by the Supreme Court of Tennessee in 1969.13 In 1970, however, the Supreme Court of Wisconsin rejected this precedent and held that a revolving charge account agreement of the J.C. Penney Co. was usurious under the state's usury law.14 it is interesting to note that the Wisconsin Supreme Court relied heavily on a decision in Nebraska, one of only two states that rejected the Time Price Doctrine, which concerned a transaction involving the assignment of a conditional sale contract 9 45 Am. Jur. 2dInterestand Usury, 123; 91 C.JS. 18b, 589; 3 A.L.R. 3d 1077-84. Sloan v. Sears, Roebuck and Co., 308 S.W. 2d 802 (Ark. 1957); Lloyd v. Gutgsell, 124 N.W. 2d 198 (Neb. 1963). 11 Ark. Const. Art. XIX, 13. 12 Neb. Law Spec. Sess., ch. 3 (1963) amending Neb. Const. art. 111, 18, Neb. Rev. Stat., 45-204 to 208 (1968). 13 Uni-Serve Corporation v. Commissioner of Banks, 207 N.E. 2d 906 (Mass. 1965); Dennisv. Sears, Roebuckand Co.,446 S.W. 2d 260(Tenn. 1969). 14 State v. J.C. Penney Co., 179 N.W. 2d 614 (Wisc. 1970). 10 23 which had incorporated on its face a promissory note payable to a finance company as assignee.15 The facts in the Nebraska decision hardly seem typical of a normal retail installment sale contract, much less a retail revolving charge account. While the Wisconsin case was pending and shortly after the decision, a number of individual and class actions were filed in other jurisdictions, including Iowa, South Dakota, New Jersey, Indiana, Connecticut, Maine, District of Columbia, California, Montana, Colorado, and West Virginia. In each of these states, the principal issue was similar-whether the time price doctrine or the usury law should apply to finance charges under revolving charge account transactions which otherwise exceeded state interest rate ceilings. To date, only two states, through a court of Appellate jurisdiction, have followed the decision of Wisconsin v. J.C. Penney. In December of 1971, the South Dakota Supreme Court also held that the revolving charge account plan of the J.C. Penney Company involved usurious interest and not a true time price differential. Interestingly, the South Dakota high court did recognize good faith reliance on the Time Price Doctrine by the persons and business institutions throughout the state who would be affected and, therefore, gave only prospective application to its decision.16 In September of 1973, the Iowa Supreme Court reversed a lower court decision and held that finance charges on Younker Brothers revolving credit accounts were interest and subject to the state usury rate of 9%.17 Since these decisions, the legislatures in both South Dakota and Iowa have enacted legislation permitting finance charges on revolving accounts in excess of state usury ceilings. There were a number of lower court decisions in Minnesota and Connecticut which also followed the Wisconsin decision; however, these suits were dismissed or the judgments vacated on appeal due to intervening legislation.18 Overwhelmingly, higher courts of New Jersey, Maine, Indiana, the District of Columbia, and more recently New York and Montana have completely rejected the decision of the Wisconsin Supreme Court and held that revolving credit sales do come within the Time Price Doctrine.19 Similar litigation is, however, still pending in California and West Virginia.20 In Colorado, the cases have been settled or dismissed.21 Implications of Usury The principal danger involved with holding that usury statutes apply to revolving credit sales is that these laws generally provide for maximum rates of interest of 6% to 12%. It is generally recognized among economists that such rates are not adequate to allow lenders to make relatively large personal loans to 15 Sloan v. Sears, Roebuck and Co., 308 S.W. 2d 802 (Ark. 1957); Lloyd v Gutgsell, 124 N.W. 2d 198 (Neb. 1963). Rollinger v. J.C. Penney Co., 192 N.W. 2d 699 (S.D. 1971). 17 Iowa v. Younker Brothers, Inc., Sup. Ct. of Iowa, No. 92/55622 September 19, 1973, CCH Cons. Cred. Gd., par. 99,966. 18 State v. Montgomery Ward & Co., Montgomery Ward & Co. v. O'Neil Minn. Sup. Ct. No. 43099 and 43100 (Order to dismiss No. 37367f dated 12-10-71); Donnelly v. Sears, Roebuck and Co., Conn. Sup. Ct. No 6902, (Order to dismiss 1-2-73). 19 Sliger V. R.H. Macy & Co., 283 A 2d 904 (N.J. 1971); Maine Merchant Association, Inc. v. Campbell, 287 A 2d 430 (Me. 1972); Williams V Standard Oil Co., 228 N.E. 2d 170 (Ind. 1972); Morris v. Capitol Furniture & Appliance Co., 280 A 2d 775 (D.C. Cir. 1971); Kass v. Garfinckel, 29, A 2d 542 (D.C. Cir. 1973); Zachary V. R.H. Macy & Co., 39 A.D. 2d 111 (N.Y. Ct. App. No. 386) (Decided 12-29-72, CCH Cons. Cr. Gd. pai 99090). Cecil v. Allied Stores Corp., Montana Sup. Ct., No. 12308, Jul 27, 1973, CCH Cons. Cr. Gd. par. 98,983. 20 Fox v. Federated, Super. Ct. L.A. Co., Calif., N.D. 992,893 and consolidated cases. Meyer v. Coyle and Richardson. Cir. Ct. Kanawha Co., W.Va., No. 11414; Greer v. Sears, Roebuck and Co., U.S. Dist. Ct., So. Dist., W.Va., No. 72-80 CH. 21 Colletti v. Sears, Roebuck and Co., Dist. Ct. of Colo. Jefferson Co., No. 30210 and consolidated cases, April 1972; Goldstein v. Fashion Bar, Inc., Dist. Ct. of Colo., Arapahoe Co., No. 26605, Oct. 20, 1969. 16 24 consumers, much less allow retailers to sell on revolving credit terms where average balances and individual transactions are much smaller. For example, at a maximum rate of 10%on a revolving charge account, a purchase of $100 repaid over a period of 12 months will produce a finance charge revenue ranging from only $4 to $5, depending on the billing method used. In order to serve adequately a credit market, a creditor needs a maximum permissible finance charge rate high enough to at least cover the largest portion of his credit costs. If he cannot, cash buyers will be forced to bear part of the burden of credit costs or credit will become unavailable to the less credit-worthy segments of the market who generally are in greater need for credit. This fact has been recognized by many authorities in the field of consumer credit, as well as in the recent report and recommendations issued to Congress by the National Commission on Consumer Finance and the National Business Council for Consumer Affairs.22 The Issue as to Billing Methods With regard to the method of computing the balance upon which a finance charge is added under a revolving charge account, considerable debate has centered around use of the Previous Balance or "Beginning Balance" method. Under this method, a finance charge is applied to the amount outstanding at the end of the previous month's billing period before deducting partial payments made on that balance and before adding current month's purchases. Until recently, this method of computing a balance upon which the finance charge is assessed was probably the most widely used by the retailing industry. Its future is in doubt, however, because of the growing controversy over its use. There are several reasons advanced for challenging the Previous Balance method: (1) the customer is not given credit for payments made before finance charges are calculated, (2) the belief that use of the Previous Balance method results in the highest possible credit cost to the customer, and (3) the belief that customers will save substantial sums of money if other billing procedures are used instead. Recent Decisions The Previous Balance method has been upheld by the New York Court of Appeals, the highest court in New York, in the case of Zachary v. R.H. Macy & Co., decided in December of 1972,23 by appellate courts in Illinois24 and Florida,25 and by a lower court in California.26 Only one decision, in a trial court in Michigan, has held that the Previous Balance method was unlawful in a situation where the statutory language was not specific. In this case, the trial court ruled that the Previous Balance method resulted in a finance charge higher than the 1.7% authorized by the Michigan Retail Installment Sales Act and that the legislature intended to prohibit this method of computation in enacting the law.27 22 Report of the National Commission on Consumer Finance, December. 1972, 107. Financing the American Consumer, Part 1-Summary Report, National Business Council for Consumer Affairs, November, 1972, 11-12. 23 Zachary v. R.H. Macy & Co., 39 A.D. 2d 116, (N.Y. Ct. App. 1972). 24 Brown v. Marcor, Inc., 111. App. Ct., First District, Fifth Division, No. 938704, Sept. 28, 1973; Johnson v. Sears, Roebuck and Co., No. 938705, CCH Cons. Cred. Gd., par. 98,920. 25 Federated Department Stores, Inc. d/b/a Burdine's v. Pasco; Sears, Roebuck& Co. v. Hicks; City Stores Co., d/b/a Richards v. Unger; Byrons Department Store, Inc., d/b/a Jackson Byrons, Inc. v. Brockinton; Jordon March Company v. Williams, Fla. Dist. Ct. App., 3d Dist., Nos. 72491-72-503, 72-506, 72-509, March 20,1973, CCH Cons. Cred. Gd., par. 99,038. 26 Seibert v. Sears, Super. Ct. of Cal., Co. of Alameda, No. 407-558, May 1, 1972, reported CCH Cons. Cred. Gd., par. 99,164. 27 Grigg v. Robinson Furniture Co., Mich. Cir. Ct., March 13, 1974, CCH Cons. Cred. Gd., par. 98,848. 25 One of the principal issues involved in litigation concerning the Previous Balance method is applying its use under language contained in various Retail Installment Sales Acts. Generally these acts define the balance on which the finance charge is assessed as follows: 1. … computed on the outstanding balance from month to month,28 2. …computed on all amounts unpaid there under from month to month,29 3. …computed ... on the outstanding indebtedness from month to month.30 Obviously the problem is one of statutory construction and legislative intent. It would seem from the type of language used in most statutes that the legislatures did not intend to prescribe one lawful method of computing charges to the exclusion of all others. In the language of the New York ruling, "taken alone, there is nothing in the terms which would further connote that the time for computation of charges be fixed atone rather than another point in time."31 Again, this ruling states that ". . . the statute has no 'plain meaning' and that its true import can only be culled from its legislative history including the uses and practices existing at the time of its enactment, as well as the statutory scheme of which it is but a part."32 Likewise, the California ruling referred to earlier recognized that "the Office of Legislative Council rendered an opinion that the Act does not specify exclusive use of any one computational method."33 Current Legislative Actions Because of growing litigation and other problems stemming from statutory language pertaining to method of assessing finance charges on revolving credit accounts, a number of states have taken more definitive action by enacting legislation specifying the type of method to be used. As of July, 1974, ten states (Arizona, Colorado, Iowa, Maine, Maryland, Massachusetts, Minnesota, Montana, Virginia, and West Virginia)34 plus the District of Columbia have adopted language which effectively prohibits use of the Previous Balance method and requires use of some type of "average daily balance" or the "adjusted balance" method. In these states, "average daily balance" is usually defined as the sum of the daily unpaid balances (including either debits or credits or, in some cases, credits only) divided by the number of days in the billing cycle. "Adjusted balance" is defined as the beginning monthly balance less payments and/or credits. 28 California Unruh Act, 1810.2. Florida Retail Installment Sales Act 520.35; Illinois Retail Installment Sales Act 28; Michigan Retail Installment Sales Act 445.862; Texas Retail Installment Sales Act., art. 6.03.4. 30 New York Pers. Prop. Law 413.3. 31 Zachary v. R.H. Macy & Co., supra note 19. 32 Id. 33 Sibert v. Sears, supra note 26. 34 Arizona Retail Installment Sales Act, 44-6003, B, CCH Cons. Cred Gd, Ariz., par. 6126. Colorado Uniform Consumer Credit Code, 2.207 (2), CCH Cons. Cred. Gd., UCCC, par. 5067. Iowa Consumer Credit Code, 2.202, CCH Cons. Cred. Gd., par. 5062. Maine Consumer Credit Code, 2.202 (2) (A & B), CCH Cons. Cred. Gd, par. 5062. Maryland Retail Credit Accounts Law, art. 83, 153D(C)(3), Cons. Cred. Gd., par. 6034. Massachusetts Retail Installment Sales & Services Law, 27, C, 3, CCH Cons. Cred. Gd., par. 6021. Minnesota Statutes, 1971, 334.16, 1(b), CCH Cons. Cred. Gd., par 6101. Montana Retail Installment Sales Act, 74-608(d), CCH Cons. Cred. Gd., par. 6023. Virginia Laws, 1970, Ch. 616 and Laws, 1972, Ch. 666, 6.1-362,CCH Cons. Cred. Gd., par. 6018A. West Virginia Consumer Credit and Protection Act, 46A-3-103, CCH Cons. Cred. Gd., par. 5083. District of Columbia Consumer Protection Act of 1971, 28-3702, CCH Cons. Cred. Gd., par. 6132. 29 26 The Question of Rates In addition to the problems cited to this point, as always there has been continuing debate with regard to what the permissible level of finance charges should be. Some of this is reflected in the rulings applying usury statutes to revolving credit sales as noted earlier. In a vast majority of states, the typical rate of finance charge permitted on revolving credit transactions is 11/2% per month, with considerable variation as to the amounts of size of balances to which this rate applies. In recent years, however, there have been increasing attempts to reduce allowable rates of charge. Currently, six states-either by virtue of rulings to the effect that usury statutes apply or by special legislation-permit finance charges of less than 11/2% per month. These are Arkansas with .8333% (usury), Connecticut, Minnesota, South Dakota, and Washington with 1 %, and Pennsylvania with 1.25%. Six states (Utah and Ohio with 2%, Nevada and Illinois with 1.8%, Kansas with 1.75%, and Michigan with 1.7%) allow rates higher than 11/2% per month. Methods of Stating Maximum Rates Usually, maximum permissible rates of finance charge are referred to in the literature as either an annual percentage rate (such as 18%) or as a monthly percentage rate (such as 11/2%). It should be noted, however, that state laws seldom state maximum permissible finance charges in terms of an annual percentage rate. Rather, the majority of laws state ceilings in terms of a monthly percentage rate. Some eight states (such as Texas, Florida, and Georgia, for example) refer to the maximums in terms of dollars and cents, such as $.15 per $10 per month.35 This point is particularly important because in some instances it is assumed that statutes provide for a limit on the actuarial rate of charge that is permissible, such as 18% when the monthly percentage is stated at 11/2%. If this is the real intention of the legislatures, it is not clearly defined by the wording of the law text which, as indicated earlier, refers to either a maximum percentage per month or dollars and cents per month. Two recent rulings in California and New York also make reference to the fact that the legislatures intended for the ceilings to be "nominal" rates and not "effective" or "true" rates (that is, not actuarial rates).36 It is likely that this tendency to refer to maximum finance charges as 18% a year is a direct result of the Truth in Lending Act requirement to the effect that a monthly percentage rate be multiplied by 12 to arrive at a corresponding "nominal" annual percentage rate. This requirement resulting in Statement of finance charges as a nominal" annual percentage rate of 18%does not, of course, mean that the actuarial rate actually involved is 18%. The actuarial rate or "true" rate paid on revolving accounts can only be determined in retrospect and depends entirely on the monthly percentage rate used, the type of billing system applied, timing of customer purchases and payments, and the period of time to which the calculations are applied. Evidence of this fact is that the Truth in Lending Act permits a creditor to disclose the Comparative Index of Credit Cost, which is said to measure the "average effective annual percentage rate of return" of his credit plan.37 Further discussion of the theory underlying 35 See, for example, Texas Consumer Credit Code, art. 6.03 (3) (a); Florida Retail Installment Sales Act, 520.35 (3); Georgia Retail Installment and Home Solicitation Sales Act, 96-904 (b). 36 Siebert v. Sears, Roebuck &Co. of Calif., Co. of Alameda, No. 407-558, May 1, 1972, reported in CCH Cons. Cred. Gd., par. 99,164 (see Finding of Fact No. 34); Zachary v. R.H. Macy & Co., N.Y. Ct. App., No. 386. 37 See Regulation Z Federal Reserve Board, 226.2 (j) and 226.11. 27 determination of finance charge rate limits and results of unrealistically low rate ceilings can be found in Chapter 6 of this study. CHAPTER 3 ORIGIN AND DESIGN OF THE STUDY Existence of an abundance of litigative and legislative activity concerning retail revolving credit clearly should be evident at this point. Most of these efforts have concerned rates of finance charge, methods of finance charge assessment, or billing practices generally. NEED FOR THIS STUDY A reasonable observation would suggest that many of the bills that have been proposed and, in some instances, enacted into law, while no doubt well meaning in intent, have been based on little factual data concerning retail revolving credit account use. For example, attempts that have been made at both federal and state level to mandate or outlaw certain. methods of finance charge assessment, to lower permissible rates of finance charge, and to prohibit imposition of minimum finance charges are all based almost entirely on theoretical conjecture concerning the benefits of such actions to customers. At the time this study was initiated, there were no empirical data available at all concerning the impact of assessment method on customer costs. Likewise, research data on the impact of minimum charges were virtually nonexistent. MAJOR OBJECTIVES OF ANALYSIS There are three distinct purposes of this study: (1) analysis of actual account usage data obtained from computerized revolving charge records on individual customers over a 1 2-month period, (2) simulation of the impact on various account use characteristics under five different methods of finance charge assessment, and (3) analysis of demographic data providing information on customer incomes, occupations, education, age, credit use patterns, and so on. Major questions to be answered from analysis of actual usage data were as follows: 1. What size balances do revolving charge customers normally maintain in their accounts? 2. What dollar finance charges do these customers actually incur during a year? What would have been the amount of such charges had the rate of finance charge been assessed at a different rate (say 1 % per month) instead of 1 ½%? 3. What annual percentage rate of finance charge was actually paid over the 12-month period studied? 4. How often were finance charges incurred? 5. What was the distribution of finance charge assessments over the year? 6. What were the purchase and payment patterns on the accounts including such factors as the number of purchases per month, the amount of purchases in dollars per month, number of days between purchase date and billing date and between billing date and payment date? 7. What was the effect on finance charge cost to the customer from the imposition of $.50 minimum charges during the 12-month period? 8. What was the actual finance charge yield to the store from al accounts during the 1 2-month period? Concerning the simulation of other methods of finance charge assessment, major questions to be answered were as follows: 1. What amount of dollar finance charge would have been incurre4 under other billing methods? 2. What would have been the annual percentage rate paid under these methods? 28 3. What would have been the yield to the store under these methods Finally, the demographic questionnaire data were designed to provide information concerning the relationships, if any, between such factors a income, education, and certain account use characteristics as average monthly balance, finance charges paid, differences in finance charges under various methods of assessment, and customer purchase and payment patterns. Hopefully, answers would be evident for such questions as the following: 1. What is the impact of the "free ride" in revolving credit? That is, do he poor pay for the rich people's credit? 2. Do certain methods of finance charge assessment penalize the poor and unsophisticated customers? 3. Does the use of $.50 minimum finance charge impose a severe financial burden, particularly on the poorer customer? 4. Are there differences in purchase and payment patterns as a result of differences in incomes or education? DEFINITIONS In order to isolate the impact of variations in the method of finance charge assessment on the amount and distribution of dollar finance charges, it is necessary to describe the derivation of the precise balance upon which finance charges are levied. No attempt has been made to be exhaustive in the survey of possible methods of assessment, Minor variations would make these possibilities infinite. The methods under consideration have the characteristics of economic reasonableness and relative simplicity. They are paradigms of methods in fairly wide current use and are the methods most often mentioned in legislative or litigative connections. They share the common attribute that, in each case, the precise level of the finance charge is completely controllable by the users of the accounts, although the method of control is different for each method. Let us define the following identifiers: P = Previous Balance method, A = Adjusted Balance method, E = Ending Balance method, W = Average Daily Balance Including (with) Debits method, X = Average Daily Balance Excluding Debits method, T = True Actuarial Average Daily Balance, and variables: FC = Finance charge, FR = Periodic finance rate (for amounts less than the break point, i.e. $500), FB = Periodic finance rate (for amounts greater than the breakpoint, i.e. $500), N = Number of days in the billing period, NC = Number of days a payment or credit was in the system (i.e., from posting date until the end of the billing month), ND = Number of days a purchase or debit was in the system, NM = Number of payments and credits, NP = Number of purchases and debits, BP = Break point (dollar amount above which a different finance rate applies), D = Debit or purchase, C = Credit or payment, U = Accumulated unpaid finance charges from prior periods, B = Beginning balance, * Denotes multiplication. 29 Also define the following quantities: The billing methods involved are defined as follows: Previous Balance: Also known as the "Beginning Balance." Finance charges are calculated on the basis of the unpaid balance shown on the previous month's statement (unless paid in full) before deducting payments or credits and before adding current purchases. Payments are applied first to any unpaid finance charges and then to principal. If no payment is made, the unpaid finance charge becomes part of the principal balance owed. The algorithm for calculating finance charges under the Previous Balance method may be expressed as: FCP = FR*B for O< B< BP = FR*BP + FB* (B-BP) for B > BP =0 for B < SC Adjusted Balance: Finance charges are calculated on the basis of the unpaid balance shown on the previous month's billing statement less payments and credits on that balance, but before adding the current month's purchases. No particular importance is attached to the date of payment on an account. Payments are first applied to any unpaid finance charges and then to principal. If no payment is made, the unpaid finance charge becomes part of the new balance owed. The algorithm for calculating finance charges under the Adjusted Balance method may be expressed as: FCA = FR*(B-SC) = FR*BP + FB*(B-BP-SC) for 0 < (B-SC) < BP for (B-SC) > BP 30 =0 for B < SC Ending Balance: Finance charges are based on the balance owed at the end of each billing period, including purchases, payments, and credit occurring during the current month. Payments are applied first to any unpaid finance charges before application to principal. In the event no payment made, the unpaid finance charge becomes part of the principal balance owed. Note that no "free ride" is given the customer if he pays his account in full unless there is, indeed, no outstanding balance at the end of the month. The algorithm for calculating the finance charge under the Ending Balance method is: FCE = FR*(B-SC+SD) = FR*BP+FB* (B-SC+SD-BP) for 0 < (B-SC + SD) < BP for (B - SC + SD) > BP. Average Daily Balance Including Debits (Method W or ADBW): Finance charges are based on the "average" unpaid balance owed during the billing period. This includes all purchases, payments, and credits transacted during the billing period. It is calculated by taking the sum of the daily unpaid balances, excluding unpaid finance charges, divided by the number of days in the billing period. Payments are applied first to any unpaid finance charges then to principal. In the event no payment is made on the account, the finance charge is carried forward as a memo balance (i.e., a balance upon which no finance charges are assessed) until a payment sufficient to cover the unpaid finance charge is made. Under this method no finance charge is imposed if the account has a zero balance at the beginning of the billing cycle or if at any time in the billing period the total of payments and credits is equal to or greater than the beginning balance. The algorithm for calculating the finance charge under the ADBW billing method is: FCW = FR* (SDB - N*U) N for O < SDB - N* U < BP N = FR*BP+FB* (SDB - N*U - N*BP) N for SDB - N*U>BP N =0 for B < SC Average Daily Balance Excluding Debits (Method X or ADBX): Sometimes referred to as "modified" average daily balance, this method calculates finance charges on the basis of an "average" monthly balance which is computed by taking the sum of the daily unpaid balances (excluding the sum of the daily debit balances and unpaid finance charges) and dividing by the number of days in the billing cycle. Thus, unlike the "adjusted" balance method, the timing of the payment will affect the size of the finance charge. Payments are applied first to any unpaid finance charge, then to principal. In the event no payment is made, the unpaid finance charge is carried forward separately, not as part of the principal balance, until payment in sufficient amount to cover the unpaid finance charge is made. No charge is imposed if the account has a zero balance at the beginning of the billing period or if during the period the total of payments and credits equals or exceeds the opening balance. 31 The algorithm for computing finance charges under the ADBX billing method is: FCX = FR* (SDB - SDDB - N*U) N for 0 < SDB - SDDB - N*U <BP N = FR*BP + FB*(SDB - SDDB - N-U - N-BP) for SDB – SDDB – N*U > BP N N =0 for B < SC "True" (Actuarial) Average Daily Balance (Method T or TADB): Finance charges are based on the "average unpaid balance during the billing period, including all purchases, payments, and credits on the account during the period. It is calculated in exactly the same way as ADBW except that finance charges are assessed on the average daily balance whether or not the account was paid off during the month, i.e., there is no "free ride" under this billing method as there was with ADBW. The algorithm for calculating finance charges under the "True" Average Daily Balance method is: FCT= FR*(SDB-N*U) N for 0< SDB-N*U < BF N = FR*BP+FB* (SDB-N*U-N*BP) N for SDB-N*U >BP. N Other useful definitions are: Billing Cycle: A billing cycle is a collection of accounts (in this case randomly selected) which have their finance charges computed on a specific day of the month (cycle date). Billing Month: A billing month is a time period ranging from 28 to 3 days which begins on the cycle date and ends the day before the cycle date in the following calendar month. RELATIONSHIPS BETWEEN BILLING METHODS In the most general sense, the six billing methods analyzed are b variations on a theme. They relate more or less closely to one another-sometimes in obvious ways, often in more obscure ways. F example, Adjusted Balance is Previous Balance with credit being given I payments made during the billing month. Ending Balance is identical Adjusted Balance with all purchases debited to the account prior to billing should be noted that in the latter case there is no possibility of free time unless the account is paid off and no purchases are made during the month, while the former cases, merely paying off the account at any time is sufficient to forestall the assessment of any finance charges. The disallowance of free time under both the True Actuarial ADB method and the Ending Balance method is the most important reason that these methods involve higher costs, in general, than the other methods. This is not, however, universally true. Unless the account is paid off, Previous Balance charges will exceed Ending Balance charges whenever payments and credits exceed purchases and debits over the billing period. Note also that finance charges under Adjusted Balance can at no time exceed those assessed under either of the other methods, although it is often possible that they will be equal. 32 Average Daily Balance Methods The three ADB methods are also closely related. The ADBX method disregards increases in the average daily balance resulting from current month's purchases but gives the consumer credit for decreases in the average daily balance due to current month's payments and credits. ADBW takes both into account in figuring finance charges as does True ADB. The two latter methods differ only in that True ADB assesses a finance charge whenever there was any balance active within the month, while ADBW makes no assessment when the account is paid off. These constructions dictate certain relationships between the three ADB methods. First, ADBX finance charges can never exceed ADBW charges. They can, however, equal one another as, for instance, when there are no purchases during a billing period. Second, ADBW finance charges can never exceed True ADB charges. These can also be equal and are, in fact, whenever the account is not paid off, regardless of any other activity. It is worth noting that the main argument against True ADB vs. ADBW is its administrative complexity. Since the two methods are functionally equivalent while a balance is maintained, it is easily seen that, in those cases in which the account is paid in full and no new purchases are made, a finance charge assessed on the average daily balance in existence for some period during the month would be billed alone in the subsequent month. This amount would, typically, be small relative to usual monthly payments and would often be disregarded by consumers. In addition, the collection expense associated with these amounts would usually be large relative to the possible revenues. ADB Vs. Non-ADB Methods Non-ADB methods can be thought of as ADB methods applied under a set of very restrictive assumptions about the timing of debits and credits to the account. For example, Previous Balance works the same as ADBX when all payments are assumed to be on the last day of the billing cycle. Likewise, the Adjusted Balance method can be thought of as analogous to the ADBX method in which all payments are applied to the account on the first day of the billing period. In this instance, in essence, the consumer received credit for the entire period regardless of when payments are received. The Ending Balance method, on the other hand, is analogous to a True ADB or ADBW method in which payments are applied to the account on the last day of the billing period and purchases are added as of the first day of the period. Thus the consumer receives no credit for payments made early in the period but may be charged for carrying receivables associated with purchases as if they had been made at the first of the month, regardless of actual date of purchase. Perhaps the most interesting relationship is that between ADBW am Previous Balance, both because many recent changes in billing method! have involved switches to ADBW and because of the functional equivalence of the two methods under certain commonly encountered circumstances Whenever purchases and payments are spaced evenly over a billing period and the balance is allowed neither to decline or increase, the finance charges assessed under either method will be equal. Such behavior does, c course, result in an Average Daily Balance equal to the Previous Balance. This rigid requirement is not frequently met since purchases are often bunched on one or several days and usually no more than one payment is made per month. In large samples, however, it is quite possible for the average behavior to approximate closely the requirements just describe( For example, if, once again, the average balance for all accounts neither increases nor decreases and if purchases and payments are symmetrically distributed about the middle of the billing period, the average daily balance and hence the 33 finance charges will be equal. The results of the study bear out this approximate relationship and the difference between the average finance charges under the two methods is insignificant. A few other relationships are noteworthy. First, since Adjusted Balance is operationally analogous to an ADB system with all credits applied on the first day of the billing period, it is obvious that Adjusted Balance can never exceed any of the ADB methods. In fact, finance charges under an Adjusted Balance system cannot exceed those under any other method since the base of assessment under Previous Balance or Ending Balance is at least equal, the base of assessment under Adjusted Balance. Second, ADBX finance charges can never exceed those assessed under Previous Balance since most the average daily balance is equal to the initial balance in the billing period. SAMPLE DESIGN The sample under study in this study consists of 865 accounts drawn from a population which at the beginning of the sample period stood 679,927. This represented .13% of the total. The period of activity studied began in December, 1970, and continued for one year through December 1971. The questionnaire appears in Appendix A and a summary of t responses to the questions can be found in Appendix B. It was determined that, for sampling purposes, no systematically biasing procedure was used in the initial assignment of a credit customer to a billing cycle. That is, there was an equal probability of assigning a new credit account to each of the 12 billing cycles available. With this in mind, a random billing cycle was chosen (the sixth cycle which had a cycle date falling on the twelfth day of each month). It was also determined that a systematic selection of every fortieth account in the billing cycle would yield the desired total number of accounts for the study. A random starting account was selected and every fortieth account was sampled until the cycle was exhausted. If the account selected proved ineligible, the following account was chosen. Ineligible accounts were those displaying the following characteristics: 1. 2. 3. 4. 5. Employee accounts, Extreme past-due accounts, Transferred accounts (either in or out) during the year, State of residence other than Texas, New account during year. The 865 accounts originally sampled were distributed on a pro rata basis among all retail outlets for this chain within the state of Texas. The number of accounts from each store averaged 28, and ranged from 2 to 236. No figures are available on the proportion of Texas retail credit card holders who are also Sears credit card holders, but the comparable national figure is 44%. Thus, the present study could be a useful picture of credit card usage in general and in retail applications in particular. 34 When an account was selected and was determined to be eligible, a one-year account history was assembled. The following items of information were collected: 1 . An account identifier, 2. The balance at the beginning of the sample period, 3. All transactions to the account over a one-year period including: a. Credits b. Debits c. Payments d. Finance charges, 4. Transaction codes, 5. Transactions dates. This account information was coded on worksheets and assembled in chronological order in preparation for key punching. METHODOLOGY This study is logically divided into two separate approaches. The first of these is the larger sample of 865 respondents. It deals with a technical description of account activity and the behavior of account revenues under an alteration of environments. Its most salient purpose is the isolation of the influence of billing method redefinition upon the finance charges assessed in the most typical of cases. The 865-Account Sample Briefly, the procedure employed is one of simulation of revolving charge activity. Purchase and payment patterns are taken as invariant under each 4 the various billing methods assumed. However, it is in the nature of these methods to produce, under simulated conditions, divergences in the finance charges that would be assessed under each. Further, the rules dictated under the billing method definitions produce exact amounts of month finance charges. However, the relationships among amounts assess under different methods or even the levels of finance charges are not obvious without detailed examination. These relationships are even less clear when the entire sample or the whole population is considered at once. The calculations by hand of, particularly, the Average Daily Balance finance charges is very tedious and more prone to error. The lack of simple analytic solutions to the problem, coupled with the very large volume of data, make the simulation technique the only viable approach to the study of these accounts. In the simplest terms, then, the data on punch cards as described above were entered into the program. The first procedure involved sorting the transactions by month and date and balancing each month's activity assure accuracy and conformity with the practices followed in the original billing system. For these purposes, the Previous Balance billing method was reconstructed and the simulated finance charge was computed for the method. The simulated amount was then compared with the actual finance charge (also assessed under Previous Balance) and, if the two values fail to agree, an error message was generated and the account was pulled for manual inspection. Once the account was found to be in order, similar finance charges were obtained for each of the assessment methods outlined in the definitions section. The simulation procedure is straightforward—all of the information necessary to calculate balances and finance charges was available. However, certain important assumptions need to be made regarding the behavior of the credit users. First, if the user paid off his entire account under the Previous Balance method, it is assumed that he would do so under any other billing method. Second, any partial payment (usually the minimum amount 35 due) would be unaffected by the billing method in use. The transaction sizes, dates, and occurrences are not influenced by bill method. The major objection to these assumptions is that they deny a change in behavior under conditions of changing credit costs. Such changes are likely to be manifested in a decision on whether or not to pay the account in full on a monthly basis if finance charges become excessive. It would be foolish claim that consumer behavior would be wholly unaffected by alteration the way in which finance charges are assessed. However there are several reasons for believing that this is not an unreasonable assumption. First, finance charges are not large in relation to the typical balance-usually one to two percent and, thereby, would likely be held in less regard than the factors which determine the timing of purchases and payments. Even if this were implausible, the maximum average difference between the actual finance charge and the most expensive finance charge amounts to less than one-quarter of one percent of the average outstanding balance. This amount may be noticeable, but it is hardly sufficient to cause large changes in expenditure and remittance behavior. Second, most payments followed predictable patterns. Customers typically either paid the account in full, paid only the minimum amount due, or omitted the payment (for that month). Payment in full is assumed under all the methods when this occurs under the actual billing method, so this poses no particular problem. Only rarely does the minimum amount due differ between billing methods, since this is a fixed dollar figure so long as the balance owed falls into a very wide range of balances, all of which call for the same minimum scheduled payment. Finally, an omitted payment is treated largely the same regardless of billing method employed. It seems unlikely, then, that a user of credit would display much reaction to a change in billing practices by altering the size of his payments. The timing of purchases within billing months has no particular impact on the finance charges assessed under most billing methods. Only when the True Actuarial or Average Daily Balance Including Debits methods are employed does timing become a factor in the magnitude of the finance charges. In the case of small balances timing is insignificant, but if balances are large, earlier and larger payments may result in somewhat reduced finance charges. Once the accounts have been balanced and alternative finance charge assessments calculated, the results are stored for later, aggregation. A wide variety of derivative figures are retained including means and standard derivations of balances and finance charges under each method, true actuarial average daily balances, account payoffs, numbers of monthly debits and dollar volumes per month, numbers of finance charge assessments, payment timing, finance rates, and differences in finance charges between pairs of billing methods. A number of descriptive statistics are derived from these collected figures and are displayed in tabular form. It is with these figures that the first part of the study concerns itself. 36 TABLE 3-1 COMPARISON OF CERTAIN CHARACTERISTICS OF THE ORIGINAL SAMPLE OF 865 ACCOUNTS WITH THE 550 RESPONDENTS TO THE DEMOGRAPHIC QUESTIONNAIRE Item 1. Average monthly balance 2. Average monthly dollar finance charge 3. Average monthly dollar finance charge on those accounts actually paying a finance charge 4. Average number of months finance charge incurred 5. Average APR, all accounts 6. Average APR, by those accounts paying a finance charge 7. Average number sales per account per month 8. Average dollar volume per month per account 9. Average number of days--purchasing date to billing date 10. Average number of days—billing date to payment date 11. Accounts that always paid a finance charge 12. Accounts that never paid a finance charge part of the time 13. Accounts that paid a finance charge part of the time 14. Difference between PB and adjusted balance 15. Difference between PB and ADBW 16. Difference between PB and ADBX 17. Difference between PB and TADB 18. Difference between ADBW and ADBX 19. Difference between Adjusted Balance and ADBW 20. Difference between Adjusted Balance and ADBX 21. Previous Balance yield to store Mean 865 $91.90 $1.24 550 $90.85 $1.22 Median 865 550 #37.27 #38.33 $.31 $.31 $1.68 $1.68 -- -- 5.16 5.13 3.0 3.0 11.64% 15.7% 11.16% 14.40% 15.5% -- 13.44% -- .95 .98 .67 .75 $19.85 $20.17 $13.89 $15.51 15.90 15.93 16.0 15.76 14.77 14.91 15.09 15.00 24.6% 24.5% -- -- 26.1% 27.6% -- -- 49.2% 47.8% -- -- $.15 $.15 $.04 $.05 $.01 $.06 -$.23 $.07 $.00 $.06 -$.24 $.07 $.00 $.02 -$.17 $.00 $.00 $.02 -$.17 -- -$.15 -$.15 -$.03 -$.02 -$.08 -$.09 -$.02 -$.02 15.928% 15.82% -- -- Source: This and all tables in the following chapters derive from a 12-month history of account records and responses to the demographic questionnaire (Appendices A and B) 37 The 550-Account Sub sample The second part of the study involves the sub sample of 550respondents to a questionnaire mailed to each of the originally selected 865 accounts. The questionnaire was concerned with the following items: 1. Numbers and types of credit cards in use, 2. Relationships and experience with banks and other financial institutions, 3. Employment and occupation, 4. Demographics-marital status, dependents, housing status, education, age, sex 5. Income 6. Credit card usage, 7. Experience with billing errors, 8. Attitudes on billing practices, 9. Knowledge of billing procedures and conventions. The questionnaire and analysis procedures made provision for unanswered and "don't know or no opinion" categories. It was of particular importance to show that the sub sample gave a relatively unbiased picture if inferences were to be drawn about the larger sample and the entire population of cardholders. This was done by comparing the account data of the sub sample to that of the large sample. The results of that comparison are in Table 3-1. In no case did the means or medians for the small sample depart far from those for the larger group. The data were coded, assembled, and the same set of descriptive statistics were computed as in the previous sample. The demographic data were merged with the account data and extensive cross-tabulations were performed. It is with these figures that the bulk of the ensuing study is concerned. 38 CHAPTER 4 REVOLVING CREDIT-CHARACTERISTICS OFACCOUNTUSAGE Retail revolving credit is a rather distinct and unique form of credit purchasing. It bears similarities to other types of consumer credit, but several factors make it imperative that economic policies and legislative decisions dealing with this type of credit be made with full recognition of its uniqueness in certain key areas. For example, revolving credit is fundamentally different from automobile and other installment credit in average balances maintained, frequency of monthly or annual usage, payment patterns, and so on. Costs and revenues associated with closed end credit plans are usually subject to a priori estimation and analysis, where open-end revolving credit plans are characterized by constantly changing balances controlled by customer purchase and payment patterns and by store-imposed credit limits. These factors clearly become significant in decisions regarding an appropriate level of finance charges and the manner in which such charges are imposed. The purpose of this chapter is to explore empirical findings measuring some important characteristics of revolving credit usage, including size of monthly balances, volume of purchase activity, finance charges paid, and patterns of usage. SUMMARY OF MAJOR CHARACTERISTICS An impression of account use may be obtained from data presented in Table 4-1. It is evident, for example, that consumer revolving credit involves much smaller amounts of money than many other forms of consumer credit since the average monthly unpaid balance for those accounts studied during the 12-month period was $91.90; one-half of the accounts averaged balances of $37.27 or less (the median balance). Finance charges were incurred in slightly over five months during the year on the average, with an average monthly finance charge for all account of $1.24, or $14.88 annually. Typically, an account was active almost nine months out of the year with an average of one purchase per month and monthly dollar sales volume near $20. The normal period between purchase and full or partial payment was 31 days, split about evenly between sales date and billing date and between billing date and payment date. Three distinct types of customers were isolated: (1) those who never paid a finance charge as a result of always paying their balances in full, (2) those who always paid a finance charge (that is, never paid their account balance in full), and (3) those who incurred finance charges only part of & time. Data presented in Table 4-1 are averages for the complete sample of 865 accounts. As with any average, variations are obscured. In an attempt to provide a better understanding of the many differences that occur in individual revolving credit account usage, several of the more important characteristics will be examined in detail. 39 TABLE 4-1 EMPIRICAL DATA CONCERNING SEARS REVOLVING CHARGE ACCOUNT USAGE IN TEXAS, SELECTED SUMMARY STATISTICS, 865 ACCOUNTS Item Average outstanding monthly balance Average monthly dollar finance charge, all accounts*** Average monthly dollar finance charge, based only on those accounts actually paying charges Average number of months finance charge incurred Average annual percentage rate paid, all accounts Average annual percentage rate paid by those accounts who paid a finance charge Average number of sales per month, per account Average dollar volume of sales per month, per account Average number of days between purchase date and billing date Average number of days between billing date and payment date Average number of months of account activity Number of times minimum finance charge incurred Accounts who always paid a finance charge ................... Accounts who never paid a finance charge ............. ....... Accounts who paid a finance charge part of the time ...... Mean* Median** $91.90 $ 1.24 $37.27 $ .31 $ 1.68 5.16 11.64% 3.00 14.40% 15.65% .95 $19.85 .67 $13.89 15.90 16.00 14.77 8.89 .51 213 or 226 or 425 or 15.09 10.00 .00 24.6% 26.1% 49.2% * An arithmetic average of monthly averages for all individual accounts. ** The midpoint in a series of data, indicating that one-half of the accounts had a value of this much or more and one-half had values of this much or less. *** Billing method actually used on the accounts sampled in this study was the Previous Balance. Finance charges were on the following basis: on that part of the Previous Balance between $33.33 and $500, the monthly rate of charge was 11/2%; on that part of the Previous Balance in excess of $500 the monthly rate was 1 %; on balances from $1 to $33.33, a finance charge of $.50 was assessed. SIZE OF BALANCE AND VOLUME OF PURCHASES Wide variations occurred in the size of account balances maintained by those customers included in this study. The range of balances included two customers with credit balances (up to $7.09 on a yearly average basis), and one with an average balance of $741.26. Table 4-2 illustrates the distribution of the mean outstanding balances for all customers. Many accounts run smaller average balances than is often imagined. Table 4-2 shows that some 40% of the customers in the sample owed an average of about $22.50 a month or less; at least 60% averaged about $60 or less; some 20% averaged between $60 and $165; and only 10% averaged more than $264.94. It should be noted that months in which no balance was owed were included in calculations of the average monthly balance, 40 resulting in smaller figures than would be obtained if only months in which amounts were owed were used. Nevertheless, the results do represent the amount of business actually transacted on revolving credit during the 12 months studied (assuming the monthly average times 12). One factor which might contribute to the relatively small size of the accounts studied is that Sears also offers a closed-end credit plan on which major appliances and other big-ticket items may be financed. Stores carrying durable goods and offering only revolving credit accounts may tend to have somewhat larger balances than the accounts included in this sample. The author has completed one other study of a Texas retail chain offering only revolving credit and with comparable merchandise in which the average monthly account balance was approximately $178, almost twice that in the present sample. Likewise, a project recently completed in the state of New York covering the credit operations of 17 stores indicated account balances generally higher than the $91.90 average balance in this study.1 In any event, however, it should be evident that the nature of revolving credit accounts is substantially different from many other types of consumer credit transactions, such as bank loans and bank charge plans -the latter in 1972 averaging about $230 a month according to the Federal Reserve Board.2 SIZE OF BALANCE IN RELA TION TO HOUSEHOLD INCOME AND EDUCATION Ordinarily, one might expect the size of account balances to be related to level of income. For some unexplained reason, however, as indicated by the data in Table 4-3, there would seem to be no clear-cut pattern relating size of account balance to household income. TABLE 4-2 AVERAGE MONTHLY UNPAID BALANCES, PREVIOUS BALANCE METHOD (865 Accounts) Decile* 1st 2nd 3rd 4th 5th 6th 7th 8th 9th 10th Average (Decile break points $3.52 7.29 13.48 22.56 37.24 60.17 103.31 165.06 264.94 741.26 * Deciles serve to divide a frequency distribution into ten equal parts constituting useful points of reference for describing a distribution. For example, the 4th decile value of $22.56 indicates that in a distribution of 865 average monthly account balances, 40% of the values in the distribution were $22.56 or less. 1 Touche Ross and Company. Economics of New York State Retail Store Revolving Credit Operations for the Fiscal Year Ended January 31,1973, (September 7, 1973). 2 "Trends and Developments in Credit Card Banking," a speech by Andrew F. Brimmer before the National Economists Club, Washington, D.C., (September 7, 1972). 41 The largest average account balance by income group was $105.42 for customers with incomes of $10,001 to $15,000. Paradoxically, the smallest average account balance of $58.96 did not occur in the lowest income level, but rather in the $7,501 to $10,000 group. Likewise, customers in the $20,001 to $25,000 income group had a smaller average account balance ($80.85) than did the lowest income level ($88.28). In some ways, the median values on account balances in Table4-3 may be more typical of account behavior than the mean figures. Generally the medians display similar patterns. That is, the highest balances are maintained by middle income groups ($10,000-$20,000). Likewise, families with incomes of $7,501 to $10,000 had the smallest balances. Unlike the mean values, however, median figures show that the lowest income level also displays much smaller balances than most other groups. There is little variation in size of balance by education level (see Table 4-4), with the monthly averages ranging from a low of about $79 to a high of less than $100. VOLUME OF PURCHASE ACTIVITY Although practically no significant variations in balance size can be ascertained among various groups by income or education levels, these same factors appear very significant in the probability of having a Sears Revolving Charge Account and in the volume of purchases made in the account. As can be determined from Tables 4-5 and 4-6, holders of these accounts are most likely to have household incomes between $10,000 and $20,000 and to be high school graduates. TABLE 4-3 AVERAGE MONTHLY ACCOUNT BALANCE BY INCOME GROUP Household N Income $7,500 or 52 less 7,501-10,00054 10,001146 15,000 15,001129 20,000 20,00169 25,000 25,001 or 88 more Total* 538 $50.00 $50.01 to $100.01 to $150.01 to $200.01 to $250.01 or Mean Median or less $100.00 $150.00 200.00 $250.00 more # % # % # % # % # % # % 31 59.66 11.54 7.7 5 9.6-- -- 6 11.5$88.28$27.59 33 73 61.110 50.016 18.52 11.019 3.7 5 13.011 9.33 7.58 5.61 5.519 1.9 58.96 25.44 5.5 105.4250.36 67 51.921 16.313 10.17 5.48 6.213 6.2 95.62 47.07 43 62.36 8.7 5 7.2 4 5.84 5.87 10.180.85 33.62 56 63.612 13.64 4.5 2 2.33 3.411 12.593.23 38.16 303 56.371 13.247 8.7 34 6.326 4.857 10.6$90.85$38.33 * Omitting 12 respondents that did not answer the question concerning income. 42 TABLE 4-4 AVERAGE MONTHLY ACCOUNT BALANCE BY EDUCATION GROUP Education Mean Median Grade school Some high school High school graduate Some college Undergraduate college degree Some post-graduate Advanced degree $86-91 82.78 92.24 99.08 78.75 89.34 90.75 $43.85 37.92 57.99 35.73 36.69 31.45 43.39 Total sample $90.85 $38.33 Table 4-5 shows that average dollar sales per month increases consistently with the level of household income and is more than twice as large for families with incomes over $25,000, as compared to those with incomes of $7,500 or less. Likewise, Index values in Table 4-5 display a consistent pattern indicating that higher-income families account for a greater than relative share of total sales volume compared to lower income groups (for example, $7,500 or less has an Index value of 68.3; $25,001 or more has a value of 139.1). Similarly, Index values in Table 4-6 show a tendency for families with greater levels of education to account for a larger than proportionate share of total sales volume. TABLE 4-5 TOTAL DOLLAR SALES VOLUME BY INCOME GROUP Household Income N Percent of Average monthly Total dollar Percent of Sample (A) Sales volume Sales by group Total dollar Sales (B) $7,500 or less 52 9.45 $13.77 $8,590.44 6.45% 7,501-10,000 54 9.82 15.15 9,814.92 7.37 10,001 – 15,000 146 26.55 19.92 34,897.80 26.21 15,001-20,000 129 23.45 20.23 31,322.88 23.52 20,001-25,000 69 12.55 21.78 18,034.56 13.54 25,001 or more 88 16.00 28.05 29,621.88 22.25 Total 538* 97.8%* $20.17 $133,154.22 99.34%* * Omitting 12 respondents that did not answer the question concerning income. 43 Index B/A 68.3 75.1 98.7 100.3 107.9 139.1 --- TABLE 4-6 TOTAL DOLLAR SALES VOLUME BY EDUCATION GROUP Education N Grade school Some high school High school graduate Some college Undergraduate College degree Some post-graduate Total 24 47 148 123 86 Percent of Average monthly Total dollar Percent of Sample (A) Sales volume Sales by group Total dollar Sales (B) 4.4% $16.24 $4,675.92 3.25% 8.5 16.16 9,116.16 6.8 26.9 18.56 32,958.36 24.8 22.4 19.66 29,025.36 21.8 15.6 23.39 24,141.00 18.1 57 10.4 547* 99.5%* 21.64 $20.17 14,802.00 $133,154.22 11.1 100.0% Index B/A 79.5 80.0 92.2 97.3 116.0 106.7 --- *Omitting three respondents that did not answer the question regarding education. CREDIT CARD USE BY INCOME As was mentioned, actual account history data indicated that a larger volume of purchase activity was associated with higher income groups, and with higher levels of formal education. Certain questions regarding general credit card use included on the demographic questionnaire mailed to all account-holders indicate the same results. As evidenced in Table 4-7, higher income levels show a much higher level of monthly credit card usage. For example, of customers with incomes of $7,500 or less, only 35% use their cards 5 or more times per month, whereas among those with incomes of $25,000, almost 90% use their cards that often. DOLLAR FINANCE CHARGES INCURRED It seems that consumers often feel that revolving credit in particular costs them more than many other forms of credit. In answers on the questionnaire concerning the cost of revolving credit, over 90% of those expressing an opinion overstated its cost (see Chapter 6 for details). Likewise, complaints about rates of finance charge were more numerous than any other single point of contention (however, even complaints about rates were relatively rare). Perhaps this feeling results from the fact that under revolving credit plans customers usually receive statements every month in which there is account activity, often including a finance charge. In contrast, on closed-end plans they are often not made aware of finance charges except at the time of initially signing the contract. Although these charges may have some impact at the time, the effect is short-lived and the amount of finance charge involved is quickly forgotten. 44 TABLE 4-7 CREDIT CARD USE BY INCOME Household Income $7,500 or less 7,501-10,000 10,001-15,000 15,001-20,000 20,001-25,000 25,001 or more Number Under 5 52 65.4 54 42.6 146 32.2 129 22.5 69 18.8 88 11.4 N* of times credit cards and accounts used per month 5-9 10-14 15-19 20 or more NA All 28.8 38.9 42.5 37.2 21.7 13.6 5.8 16.7 15.8 23.3 23.2 31.8 --2.7 5.4 17.4 8.0 --6.2 10.9 17.4 35.2 -1.9 0.7 0.8 1.4 -- 100% 100 100 100 100 100 *Omitting 12 respondents that did not answer the question concerning income. A realistic picture of the actual cost of revolving credit over an extended period is provided by data presented in Table 4-8. The average monthly finance charge incurred was $1.24, or $14.88 for the 12-month period studied. On each account, the months in which no finance charges were incurred were included in the averages. Accounts on which no finance charge was assessed at all during the year (that is, customers who always paid their account balance in full upon receipt of statement, thereby avoiding the imposition of finance charges) were also included in calculations of these averages. if analysis of confined only to those customers who paid finance charges one or more times during the year (that is, omitting customers who paid no finance charges at all), average monthly dollar finance charges amounted to $1.68, or $20 annually. TABLE 4-8 AVERAGE MONTHLY DOLLAR FINANCE CHARGES INCURRED, PREVIOUS BALANCE METHOD (865 Accounts) Decile Average Dollar Finance Charge (Decile break points) 1st $.00 nd 2 .00 3rd .04 4th .13 5th .31 th 6 .64 7th 1.45 8th 2.37 th 9 3.94 10th 9.91 Mean $1.24 Table 4-8 provides additional insight into payment of finance charge not evident in the “average” figures. At least one-half of the accounts were assessed average monthly finance charges of $.31 or less ($3.72 for the year); another 20% of the customers paid charges ranging from $.32 to $1.45 monthly. Only about one-fifth of all accounts incurred average monthly charges greater than $2. The absolute highest average finance charge incurred was $9.91 on an average monthly balance of $741.26. 45 Patterns of Finance Charge Assessment As to the frequency of finance charge assessment, it is possible to identify three major groups of accounts as follows: (1)those who never paid a finance charge during the 1 2-month period, that is, those who always paid their account balances in full upon receipt of statement, 26.1 % of the total sample; (2)those who always paid a finance charge because they made only a partial payment on their account balance and never paid it in full, 24.6%of the total sample; (3) those who incurred finance charges one or more times during the 12-month period but not every month, 49.2% of the total sample. Impact of the "Free Ride" Concern has been expressed about the fact that some customers avoid finance charges by paying their outstanding balances in full each month. It is often alleged that the ability to do so is confined largely to upper income groups and, as such, there is a clear-cut case of the "poor" subsidizing the rich.3 Data are presented later in this chapter concerning assessment of finance charges as related to level of household income. At this point, it is appropriate to examine the significance of the "free ride" argument. To this end, Table 4-9 summarizes some usage characteristics according to frequency of finance charge assessment. Customers who never paid a finance charge (26% of the sample) accounted for only 4.2% of total balance activity on all accounts during the year. These families maintained an average monthly account balance of only $14.78, far below the average for the total sample ($91.90). They also accounted for some 23% of total credit sales volume during the 1 2-month period—less than their relative share when their percentage of the total sample (26%) is considered. Customers who always paid a finance charge (24.6% of total sample), on the other hand, produced 64% of total balance activity. This group maintained an average monthly balance of about $240, far above the average balance for all accounts ($91.90). The percentage of total finance charge revenue paid by this group was 71%, slightly more than their percentage of the balance activity. They accounted for 29% of total annual credit sales volume—more than their relative share of the sample (25%). The third group of accounts—those paying finance charges only part of the time—constituted 31% of total balance activity and paid 29% of total finance charges incurred. Their average monthly balance was about $59 (lower than the overall average); they accounted for about 47% of total credit sales volume, about the same as their relative share of the total sample. Thus, there is indeed a "free ride" enjoyed by some customers, but these families actually account for a relatively small portion of total business activity in terms of balances maintained. A majority of finance charge revenue received is paid by customers who produce the vast majority of total purchase and balance activity. Therefore, evidence indicates that the impact of the so-called "free ride" is probably substantially less than offer suggested. 3 Speech by Senator William Proxmire. Congressional Record, (February 20, 1973), S-2806-7. 46 TABLE 4-9 SELECTED CHARACTERISTICS OF REVOLVING CHARGE ACCOUNT USAGE BASED ON FREQUENCY OF FINANCE CHARGE ASSESSMENT Frequency of Assessment Number of Percent of Average Percent of Accounts Total Monthly Total Balance balance Activity* Always Pay 213 24.6% $240.06 64.32% Never Pay 226 26.1 14.78 4.20 Sometimes Pay 426 49.2 58.74 31.48 Percent of Average Total sales Monthly Finance Charge 29.2% $3.56 23.2 .00 47.6 0.73 Percent of Total finance Charge revenue 70.85% .00 29.15 *Sum of individual average account balances in each group divided by total of all average account balances. Payment of Finance Charges in Relation to Household Income and Education It has been alleged that the poor and unsophisticated consumer is at an economic disadvantage in the marketplace and that he, in particular, feels the impact of finance charges more heavily than consumers generally.4 In order to examine this premise, Table 4-10 and 4-11 have been prepared from responses to the demographic questionnaire. Frequency of Assessment From data in Table 4-10, it can be seen that customers with incomes of $7,500 or less incur finance charges more frequently (5.5 times per year average) than families with annual incomes of $20,000 or more (4.4 and 3.66 times per year, average). There is also a greater tendency for families with lower incomes to "always pay" finance charges compared to families with incomes of $20,000 or more. The percentage of lower-income families who "never pay" finance charges is substantially less than in higher income groups. Although the frequency of finance charge assessment among lower income families is greater than in higher-income families, middle-income families incur finance charges more often than any other group. For example, families with incomes between $10,001 and $15,000 had a greater percentage (32.9%) of "always pay" accounts than any other income group. Likewise, this middle income group also incurred finance charges more often (6.37 times per year on the average) than any other income group. 4 Statement by Senator William Proxmire. Consumer Credit in the United States, Report of the National Commission on Consumer Finance, (December 1972), 229. 47 Table 4-10 ASSESSMENT OF FINANCE CHARGES BY HOUSEHOLD INCOME GROUPS Household Income $7,500 or less 7,501-10,000 10,001-15,000 15,001-20,000 20,001-25,000 25,001 or more No Answer** N 52 54 146 129 69 88 12 Frequency of Assessment Always Paid Never Paid Sometimes Paid Number Percent Number Percent Number Percent Mean* 15 9 48 31 15 15 2 28.8% 16.7 32.9 24.0 21.7 17.0 16.7 12 17 25 32 25 34 7 23.1% 31.5 17.1 24.8 36.2 38.6 58.3 25 28 73 66 29 39 3 48.1% 51.9 50.0 51.2 42.0 44.3 25.0 5.5 4.56 6.37 5.43 4.42 3.66 --- * Average number of months finance charge paid. ** Did not answer the income question. Similarly, families with incomes between $15,001 and $20,000 had almost as great a percentage of "always pay" accounts (24%) as did lower income families (29%). The average number of times that finance charges were assessed was almost identical for the $15,001 to $20,000 group (5.43 times per year) as for families with incomes of $7,500 or less (5.5 times per year). Thus, it would appear that it is not lower-income families which incur finance charges most often, although they do so more often than higher income families. The most frequent assessment falls on middle-income ($10,000 to $15,000) families. Share of Total Finance Charge Revenue The previous discussion dealt primarily with the question of frequency of finance charge assessment related to level of household income. A much better measure of the overall dollar impact of such assessment by level of income is provided by data in Table 4-11. The pattern displayed by the data in Table 4-11 is for the most part not unlike that shown by data pertaining to frequency of assessment. As indicated by the Index values, three income groups accounted for a larger than proportionate part of the total finance charges paid. These were, in order of impact, $7,500 or less (153.0), $10,001 to $15,000 (121.9), and $15,001 to $20,000(105.4). Of the remaining income groups experiencing a smaller dollar impact from finance charge assessment, one is definitely a below average level ($7,501 to $ 10,000); but the other two represent higher income families ($20,000 or above). The major difference between the data in Table 4-11 concerning share of total finance charges paid and the data in Table 4-10 pertaining to frequency of assessment is that the lowest income level ($7,500 or less) experience the greatest dollar impact in terms of share of charges paid but not in terms of frequency of assessment ($10,001 to $15,000 experienced the most frequent assessment). There is the possibility that the results displayed in Table 4-11 may be influenced by the relatively small number of observations occurring in some of the income groups, particularly $7,500 or less and $7,501 to $10,000. Assuming that this is not a major factor in the conclusions, it would seem that the data indicate that it is not the "poor" that feel the greatest impact from finance charge assessment; it is primarily the vast group of families with average or middle incomes (i.e., between $10,000 and $20,000). 48 Assessment of Finance Charges by Education As mentioned earlier, it has been alleged that the poor and unsophisticated feel the impact of finance charge assessment more heavily than other groups. Data in Tables 4-12 and 4-13 reflect the relationship, if any, existing between finance charge payments and level of education. From these data (see Table 4-12), it would appear that all educational groups from Grade School through Some College incur finance charges at about the same frequency (5.49 to 5.77 times per year on the average). Families where the head has a college degree or more in terms of education appear to incur charges slightly less often. TABLE 4-11 IMPACT OF FINANCE CHARGE ASSESSMENT BY INCOME GROUPS Household Income* N Percent Total finance Average Percent of total of Sample Charges paid Monthly Charges paid by By group Finance Total sample Charge ($8,021.03) (A) $7,500 or less 52 9.45% $791.40 $1.27 9.87% 7,501-10,000 54 9.82 499.80 0.77 6.23 10,001-15,000 146 26.55 2,562.96 1.46 31.95 15,001-20,000 129 23.45 1,988.52 1.28 24.79 20,001-25,000 69 12.55 871.92 1.05 10.87 25,001 or more 88 16.00 1,179.96 1.12 14.70 Total 538* 97.8%* $7,894.56* -98.41%* Percent of Index Total (A / B) Sales (B) 6.45% 7.37 26.21 23.52 13.54 22.25 99.34% 153.0 84.5 121.9 105.4 80.3 66.1 -- *Twelve (2.2%) no-answer to income question omitted. Again, data in Table 4-12 show that the percentage of families that always pay" is about the same for education levels from Grade School through Some College (25 to 29.8 %) and somewhat less for higher 11evels of education. Data on the total impact of finance charge assessment by education level are presented in Table 4-13. By comparing percentage of total finance charges paid by the group with the percentage of total sales volume accounted for by the group, a measure of the relative impact of finance charge assessment is obtained. This is expressed as an Index in Table 4-13. From these data it would seem that the impact of assessment is somewhat greater among families with lower levels of education. In fact, all education levels below Undergraduate College Degree had Index values of greater than 100, indicating a greater than proportionate share of charges paid. Two factors should be considered, however, in interpreting these findings. First, the cell size (i.e., the number of observations in a given group) is quite small (less than 50) in the two lowest education levels. This may reduce the value of these results as far as making conclusions concerning a broader universe is concerned. Second, the percentages involved for both finance charges paid and total sales are very small figures in most instances. Thus, the Index values tend to overstate the magnitude of the real differences. For example, in the Grade School education level, the percentage of total finance charges paid is 4.4 and the percentage of total sales in that group is 3.5 - a difference of less than a percentage point - but as an Index value, the result is 125.7, a figure that depicts a much greater difference. 49 RATES OF FINANCE CHARGE PAID Much controversy exists about permissible levels of finance charges on revolving credit accounts. By far the most common rate of charge allowed is 1112% per month. According to the Truth in Lending Act, this amounts to a 11 nominal" annual percentage rate of 18%. Not 18% Usually Customers using revolving credit accounts, however, do not necessarily incur charges at a "true" or "actuarial" rate of 18%. Likewise, they are no, assessed finance charges equal to $18 for each $100 financed over a period of time, assuming that the customer is reducing his balance by making the minimum required monthly payments. This point is widely misunderstood and evidence to this effect is discussed in Chapter 6. That a vast majority of customers do not actually incur finance charges at an "actuarial" rate of 18% even though the monthly rate of charge is 11/2% is a result of two factors. First, under many billing methods, including the Previous Balance system (which was used on the accounts studied in this sample), finance charges are based on an amount of indebtedness at some particular point in the billing cycle (for example, at the beginning of the month before adding current purchases and before deducting payments and credits). This amount may not be representative of the "average" amount of indebtedness over the entire billing period. The second factor is what is often referred to as "free time." "Free time," under a Previous Balance system, refers to the fact that customers do not incur finance charges when the previous month's balance is paid in full (that is, when payments and credits equal or exceed the amount owed on last month's statement). Likewise, even when a finance charge of 11/2% per month is assessed, the amount on which the charge was based may have been owed for as long as 60 days if the purchase was made at the beginning of the previous month's billing period and if payment was at the end of the current month. As indicated in the "Definitions" section of Chapter 3, all methods, except "True" Average Daily Balance, involve some of this "free" time - some more than others. Table 4-12 ASSESSMENT OF FINANCE CHARGES BY EDUCATION LEVEL Frequency of Assessment Always Paid Never Paid Sometimes Paid Number Percent Number Percent Number Percent Mean* Education N Level Grade school 24 6 25.0% Some high school 47 14 29.8 High school 148 42 28.4 Graduate Some college 123 35 28.5 Undergraduate 86 15 17.4 College degree Some post-graduate 57 14 24.6 Advanced college 62 8 12.9 Degree No Answer ** 3 1 33.3 Total 550 135 24.5% *Average number of months finance charge paid. ** Did not answer the education question. 6 14 29 25.0% 29.8 19.6 12 19 77 50.0% 40.4 52.0 5.71 5.49 5.77 30 35 24.4 40.7 58 36 47.2 41.9 5.68 3.73 17 21 29.8 33.9 26 33 45.6 53.2 4.53 4.21 -152 -27.6% 2 263 66.7 47.8% -5.13 50 TABLE 4-13 IMPACT OF FINANCE CHARGE ASSESSMENT BY EDUCATION LEVEL Education Level* N 24 47 148 Percent Average Total Percent of total of Sample Monthly Finance Charges paid by Finance Charges paid Total sample Charge By group ($8,021.03) (A) 4.4% $1.23 $354.24 4.4% 8.5 1.16 653.40 8.1 26.9 1.25 2,225.52 27.7 Grade school Some high school High school Graduate Some college Undergraduate College degree Some post-graduate Advanced college Degree Total 3.5% 6.8 24.8 125.7 119.1 111.7 123 86 22.4 15.6 1.36 .97 2,014.44 1,003.68 25.1 12.5 21.8 18.1 115.1 69.1 57 62 10.4 11.3 1.16 1.13 794.76 841.32 9.9 10.5 11.1 13.9 89.2 75.5 100.0% -- 547* 99.5%* $1.22 $7,887.36* 98.3%* * Omitting three no-answer questions on education. Percent of Index Total (A / B) Sales (B) Actual Rates of Charge Results of the analysis of actual rates of charge on the sample accounts Are presented in Table 4-14. As indicated, an average monthly rate of charge of.97% or 11.64% annually was incurred. Some 50% of the customers paid an average monthly rate of 1.2% (14.4% annually) or less. These figures are based on monthly averages for all 865 accounts included in the sample. There are at least two factors which cause the average rate to be substantially less than the stated rate of 18%. First, some 26% of the accounts incurred no finance charge at all during the 12 months - that is, had an average rate of zero but had an average balance on an 11 actuarial" basis. These reduce the overall average for all customers. Second, customers who paid finance charges during the year often had individual months in which no finance charge was incurred (even though purchases were made) because they paid the balance in full. Thus their average annual rate would be lowered. If those accounts on which a finance charge was never assessed are omitted and calculations are confined only to accounts incurring a finance charge all or at least part of the time, a higher average rate of 1.30% monthly (or 15.65% annually) results. If analysis is confined to those customers incurring a finance charge in every month in which they had a balance (some 213 accounts or 25% of the total), the average rate is higher. For these customers, the average annual rate of charge paid amounted to approximately 17.8%. The rate for these ,customers is still below 18% because the beginning monthly balance on which the charges were based was not the same as the average monthly balance. The average daily balance must be used in order for a rate to equal an "actuarial" rate of 18%. 51 TABLE 4-14 ANNUAL PERCENTAGE RATE PAID BY 865 ACCOUNTS (1 ½ % on 1st $500, 1% over $500 with $.50 minimum) Decile Average Dollar Finance Charge (Decile break points) 1st $.00 2nd .00 rd 3 4.56 4th 10.56 5th 14.40 th 6 16.32 7th 17.40 8th 17.88 9th 18.60 th 10 129.48* Mean 11.64% * Customer had beginning balance of $3.50. For four months he made no payments and was assessed a $.50 minimum charge. During the 5th month, he paid $5.50 to close out the account. This unusual circumstance accounts for the extremely high APR. Thus it should be evident that statement of finance charges as an annual percentage rate of 18% is simply a result of a legal requirement and does not reflect the actual customer cost of revolving credit over a period of time. The proximity of this federally required stated rate to the actual rate paid depends on the billing method employed by the store and on the way in which customers use their accounts. Consistently buying early in a billing cycle and making payments late lowers the actual rate of charge, while reversing this pattern raises it. It should be noted, however, that although the "true" rate of charge may vary according to the above factors, the customer cost in dollars and cents will not necessarily be affected, depending upon billing method used. Only under some type of average daily balance system would the timing of purchases and payments affect dollar cost. Rates Over 18%? It should be recognized further that all of the rates referred to above—11.6%, 15.6%, and 17.8%--are averages of results on many individual accounts. Hypothetical examples are often used to illustrate situations in which use of the Previous Balance method can result in finance rates substantially in excess of 18%. It is worthwhile to question whether such theoretical examples are representative of real-life situations. Analysis of sample data from 865 accounts indicates that use of the Previous Balance method can, under certain rigid conditions, produce rates higher than 18%. It should be noted, however, that the likelihood of that occurrence is considerably less than is often suggested by the use of artificial and hypothetical examples. In this study, only 81 accounts out of the 865 sampled - about 9% of the total - incurred an average annual rate of finance charge in excess of 18%. On 11 accounts, the average rate was exactly 18%. In 773 instances, 89% of the cases, the rate of charge averaged less than 18%. 52 In this regard, it should be recognized that these 81 accounts paid a rate of charge exceeding 18% over the 12 months studied. It is not known whether the same would have been true over the entire life of the account because of possible existence of some "free time" as explained earlier. Likewise, some of the instances over 18% may be a result of the imposition of a minimum monthly charge of $.50. Use of $.50 minimum charges can produce very high rates of charge when applied to extremely small balances (for example, less than $10). An example of this is shown in Table 4-14 referred to earlier. A more detailed discussion of the impact of minimum charges can be found later in this chapter. So, use of the Previous Balance method with a monthly charge of 11/2% can produce an actuarial rate in excess of 18%. Usually this occurs when individuals make purchases relatively late in the initial billing period and make payments relatively early following receipt of statement. If a customer takes all of the allotted time in which to make his payments (generally 25 to 30 days from statement date), the finance charge cannot exceed 18% even if the purchase is made late in the billing, but it may approach that level. Also, charges in excess of 18% are most likely to occur on accounts in which an initial purchase is made and the balance is repaid over a period of time during which no other purchases are made and payments are made early in each billing cycle. One final point on this matter is worth repeating, It cannot be assumed from a reading of the text of state laws that legislatures intended permissible finance charges to be limited to an actuarial rate of 18%. Maximums are stated either in terms of a percentage per month or dollars and cents. Seldom is reference made at all to annual rates of any kind. If, by chance, a customer should actually pay more than 18% because of some of the conditions described above, the legality or illegality of the situation would be open to dispute. In this regard, the Texas statute specifies that the rate of charge shall not exceed $.15 per $ 10 per month. It should be noted that for none of the 865 accounts included in the study did the rate of finance charge exceed $.15 per $10 per month. Neither did the monthly percentage rate exceed 11/2% (except in instances where $.50 minimum charges were imposed on balances less than $33.33, a practice specifically permitted by the statute). EFFECT OF LOWER RATES OF FINANCE CHARGE Earlier discussion has focused on the use of revolving credit accounts on which finance charges were assessed at a monthly rate of 11/2% on that part of the unpaid balance up to $500 and 1% on that portion of the unpaid balance in excess of $500. Since most customers in the sample maintained monthly balances of less than $500 (see Table 4-2), average monthly finance charges paid would not be much different from a monthly rate of charge of 11/2% on any amount, including that in excess of $500. Currently, however, five states have set maximum permissible levels of finance charge at 1% per month or less (see Chapter 2). Attempts are regularly being made in many other states to reduce the level of lawful charge below the most commonly authorized rate of 11/2%. The ensuing discussion will deal with actual and hypothetical economic effects of such legislative action. Effect of 1% on Customer Costs What are the effects of reducing charges from 11/2% per month to a lower rate of, say, 1 %? Obviously, the reduction is one-third, but the important question involves the meaning of such a reduction to an "average" or typical user of revolving credit. 53 Judging from data gathered on the sample accounts used in this study, a typical consumer could expect "on the average" to incur a monthly finance charge of $.84 under a 1% per month rate. This compares to an average monthly charge of $1.24 at 11/2% - a saving of some $.40 monthly or $4.80 annually. According to median figures, 50% of the customers could expect monthly finance charges to $.22 a month or less as compared to $.31 a month at the higher rate -a savings of $.09a month or $1.08 for the year. In determining the significance of the savings from the 1% rate, it might be useful to note that the average annual volume of purchases by the customers included in this sample amounted to approximately $242. Thus the savings from a 1% rate amount to less than 2% of average annual expenditures at the single creditor involved in this study. The overall impact of a lower rate is, of course, somewhat higher when consideration is given to all revolving credit usage rather than the activity at a single store. Responses to the demographic questionnaire indicate that typically a family had about four department store revolving charge accounts (see Appendix, Table B-1). If the volume on each of these accounts averaged about the same as that of the customers having the Sears accounts, the annual volume of revolving credit expenditures would approach $1,000 Total savings from a 1 % monthly rate over a 11/2% rate on this annual volume of purchases would amount to $20 or less yearly. The importance of this level of savings is, of course, subject to dispute. The net savings from a lower rate may be somewhat less than the $20 indicated above, however, if a creditor—because of the lower rate of finance charges—raises his cash prices. Effect of 1% on Providers of Credit On the other hand, a reduction in allowable rates below 11/2% may be critical to a retail creditor when multiplied by the large numbers of customers using revolving accounts. For example, on just the 865 accounts included in the sample used in this study, total finance charge revenue at a monthly rate of 11/2% was $12,843.13-6.2% of total sales volume of $206,056. At a rate of 1% per month, total finance charge revenue for the year would have been reduced to $8,562 - a decrease of $4,281, or one-third. This decrease amounts to approximately 2.1 % of total credit sales volume for the year. Numerous cost studies in several states have shown evidence that most retailers at best break even on their credit costs even when the allowable rate of charge is 11/2% per month.6 It is possible that retailers might tend to "break even" even if allowable rates were as high as 24% if they were to begin offering credit terms to even higher risk customers. A real problem exists, however, when a 6 See, for example, the following studies: a. Robert W. Johnson and Touche, Ross, Bailey, and Smart. Economic Characteristics of Department Store Credit. New York: National Retail Merchants Association, 1969. b. Touche Ross and Company. Cost Analysis of Retail Store Revolving Credit State of Arizona, 1970. Jan Robert Williams. "The Credit Deficiency of Retailers in Arkansas," Arkansas Business and Economic Review, (August 1970). d. Touche Ross and Company, Cost Analysis of Retail Store Revolving Credit State of California, 1970. e. Determination of Credit Revenue and Related Costs: Younker Brothers, Inc. Des Moines, Iowa: Peat, Marwick, Mitchell and Company, 1971. f. Ernst and Ernst. Retail Credit Operations Study. Minnesota Retail Federation, Inc., 1971. g. Touche Ross and Company. Economics of New York State Retail Store Revolving Credit Operations for the Fiscal Year Ended January 31, 1973, (September 7, 1973). h. Roland Stucki, Utah Consumer Credit Report. Salt Lake City: State of Utah Department of Financial Institutions, 1970. i. Touche, Ross, Bailey, and Smart. Study of Consumer Credit Costs in Retail Stores in Washington. Seattle: Washington Retail Council, 1967. 54 creditor has made his decisions as to acceptable credit risks under a statutory ceiling of 18%, has issued credit cards with no expiration date (as is typical of industry practice), and, then, suddenly is faced with a reduction in the lawful rate to 12% or less. In such instances, how does one call back or cancel credit cards? At a 1 % per month rate creditors must find alternative ways to recover credit losses. Increases in cash prices, tightening of credit policies so that certain customers with high-risk profiles cannot obtain credit, and charging for certain services (such as delivery, check cashing or parking) that previously had been "free" are among the ways that retailers can respond to losses on credit operations. A more complete discussion of the principles involved in setting maximum permissible levels of finance charges may be found in Chapter 6. EFFECT OF $.50 MINIMUM CHARGES ON CUSTOMER COST It is a common practice of many creditors to levy minimum monthly finance charges on revolving accounts with small balances. The primary economic justification advanced for the use of a minimum charge is that ,small balances do not provide enough finance charge revenue at regularly authorized rates to cover the costs of handling the account. For example, at a monthly rate of 11/2%, a balance of $20 would provide a finance charge of only $.35. It may also be argued that the imposition of a minimum charge tends to discourage the carrying forward of very small balances. Generally, a minimum charge of $.50 is imposed on balances below that necessary to yield $.50, that is, $33.33. This was the case with the 865 sample accounts analyzed in this study. Concern for Low-Income Consumers Imposition of minimum charges has brought an outcry from several sources and has resulted in statements to the effect that assessments of this type result in rates of 60% or more.7 Likewise, as mentioned earlier, efforts have been made to amend the Truth in Lending Act to prohibit this kind of charge. The primary concern of those who have expressed opposition to use of minimum finance charges is that such charges put an unfair burden on low income customers in particular—primarily as a result of their alleged tendency to incur very small balances and their inability to pay accounts in full in order to avoid imposition of minimums.8 Measurement of Actual Impact Rather than depending upon certain hypothetical situations designed to portray the nature of the problem with minimum charges (which may exist, but occur rarely), it is more accurate to present empirical results on the subject. Accordingly, a computer program was developed upon which the 865 account histories could be simulated to measure the actual impact of minimum finance charges on costs to these revolving credit customers. The methodology assumed that all purchases, payments, and account balances were exactly the same as those actually occurring during the 12month period studied. The only difference from the actual assessment method was that a rate of 11/2% per month on all balances up to $500 was applied. In other words, no minimum dollar charge was applied on balances below $33.33. 7 8 Jack Anderson, "Bank Lobby Helps Senators Kill Consumer Measures," Chicago Daily News, (April 4, 1972), 16. Speech by Senator William Proxmire. Congressional Record (February 20, 1973), S-2808. 55 As indicated earlier, average monthly finance charges incurred by the 865 accounts (including the use of $.50 minimums) amounted to $1.24. Without the use of $.50 minimums, but with all other factors constant, the average monthly finance charge paid was $1.23 - a difference of $.01 per month on the average. Frequency of Minimum Charge Assessment Additional empirical results on the impact and frequency of minimum charges is provided by Table 4-15. As indicated, no minimum finance charge at all was imposed on almost 73% of the accounts in the sample. Approximately 25% of the accounts incurred minimum charges one, two, or three times during the 12-month period. The largest number of times that minimum charges were imposed on any one account was nine, and this occurred on only a single customer out of the 865 studied. With this information in mind, it should be evident why the impact of minimum charges amounted to only $.01 per month for an average account. Even for the customer paying a minimum charge nine times during the year, the extra cost to him because of the $.50 minimum amounted to only $.87 for the entire year (his cost for the year, including the minimum was $5.13; without the minimum, his cost would have been $4.26). Imposition of Minimum Charges by Household Income and Education Even though the average difference in finance charge assessments resulting from use of $.50 minimum charges is only $.01 per month, it is still possible for the economic impact to be greater for any given income group, particularly a lower income group. To examine this possibility, information on household income obtained on the demographic questionnaire was compared to the number of times minimum charges were incurred. The results are shown in Tables 4-16 and 4-17. Data in Table 4-16 indicate that families with incomes of $7,500or less incur minimum finance charges somewhat more frequently than higher income groups. For example, the Index values for the lower income group indicate that they account for 33.7% more of the total number of times minimums were imposed than would be expected from their proportion of the sample. That is, this group represented 9.5% of the total sample but incurred 12.7% of the total minimum charges imposed on all accounts. Even though the tendency for lower-income families to incur minimum charges more frequently seems apparent, it does not mean that the overall impact of the imposition of minimums is significant even for these groups. For example, as shown in Table 4-17, no family with incomes of $7,500 or less incurred minimum charges more than 4 times during the 12-month period studied. Of the 35 families in this group which did incur minimum charges, 8 of them paid the minimum only once during the year. If a family, regardless of level of income, incurs $.50 minimum charges only four or five times during the year (overall average for all accounts was.5 times per year), the economic significance of this fact simply cannot be anything but minimal. 56 TABLE 4-15 NUMBER OF TIMES THAT A $.50 MINIMUM FINANCE CHARGE WAS IMPOSED* Number of times Number of Percent Minimum charge Subjects Imposed 0 631 72.9% 1 115 13.3 2 64 7.4 3 33 3.8 4 14 1.6 5 4 0.5 6 1 0.1 7 2 0.2 8 0 0.0 9 1 0.1 Total 865 99.9% * Imposition of a $.50 minimum charge produced an average monthly finance charge of $1.24---$.01 a month higher than would have been true had no minimum been imposed. The customer who incurred a minimum charge 9 times during the 12-month period studied paid an additional finance charge of $.87 over the 12-month period because of that minimum. TABLE 4-16 PAYMENT OF $.50 MINIMUM CHARGES BY INCOME GROUPS Paid a Minimum Household Income N $7,500 or less 7,501-10,000 10,00115,000 15,00120,000 20,00125,000 52 Percent of Total sample (A) 9.5% Number Did not pay A minimum charge Share of total paid Percent Number Percent (B) Number Percent Index B/A 17 32.7% 33 12.7 35 67.3% 133.7 54 9.8 146 26.5 15 37 27.8 25.3 32 69 12.3 26.5 39 109 72.2 74.7 125.5 100.0 129 23.5 28 21.7 60 23.1 101 78.3 98.3 69 18 26.1 31 11.9 51 73.9 95.2 12.5 57 25,001 or 88 16.0 20 more No answer * 12 2.2 1 Total 550 100.0% 136 *Did not answer the income question. 22.7 34 13.1 68 77.3 81.9 8.3 24.7% 1 260 0.4 -- 11 414 91.7 75.3% 18.2 -- 58 TABLE 4-17 FREQUENCY OF PAYMENT OF $.50 MINIMUM FINANCE CHARGE BY INCOME GROUP Number of months in whichminimum financechargewas incurred Non One Two Three Four Five Six Seven Eight Nine # % # % # % # % # % # % # % # % Household N # % # % Income $7,500 or 52 36 67.38 15.44 7.73 5.82 3.8 ---- ---- --- -- -less 7,50154 39 72.25 9.3 5 9.33 5.62 3.7 ---- ---- --- -- -10,000 10,001- 146109 74.720 13.711 7.53 2.11 0.7 1 0.7 -- ---- --- 1 0.7 15,000 15,001- 129101 78.310 7.8 12 9.32 1.62 1.6 1 0.8 -- -1 0.8--- -- -20,000 20,001- 69 51 73.910 14.54 5.83 4.31 1.4 ---- ---- --- -- -25,000 25,000 or 88 68 77.312 13.63 3.44 4.51 1.1 ---- ---- --- -- -more No 12 11 91.71 8.3 --- --- ------ ---- --- -- -answer* Total 550414 75.366 12.039 7.118 3.39 1.6 2 0.4 -- -1 0.2--- 1 0.2 *Did not answer the income question. Minimum Charges Related to Education In addition to the concern expressed about the impact on lower-income families of the imposition of $.50 minimum charges, it is often claimed that unsophisticated buyers pay these charges more often. In order to examine this premise, educational levels were related to frequency of minimum charge assessment. Results are shown in Tables 4-18 and 4-19. As indicated by the Index values in Table 4-18, there is little variation between different levels of education. In Table 4-19, it can be observed that no family in either of the two lowest education levels incurred minimum charges more than four times during the year. This evidence indicates that incurrence of minimum monthly finance charges is not related in any significant way to the level of education or sophistication of the family head. To summarize, for whatever reasons, the overall impact on costs to the individual customer from use of $.50 minimum charges is, in most instances, practically nonexistent. It may be that the possibility of incurring such a charge actually encourages customers to pay small balances in full, thereby saving them from finance charges that would otherwise by assessed. In any event, the impact of a minimum charge does not appear to be significant to an average customer, regardless of his level of income or education. In support of the use of $.50 minimum charges, in its report of December, 1972, the National Commission on Consumer Finance noted that in reference to banning use of such minimums "some customers may gain, others will lose. There is no convincing evidence that on balance consumers will be better off." Continuing, the report indicated that "minimum charges are to cover costs associated with the credit function regardless of the size of the balance. That line of argument would support minimum charges, both as a matter of equity and as a deterrent to the uneconomical use of credit."9 9 Report of the National Commission on Consumer Finance, (December 1972), 107. 59 TABLE 4-18 PAYMENT OF $.50 MINIMUM CHARGES BY EDUCATION LEVEL Paid a Minimum Education Level N Percent of Total sample (A) 24 4.4% 47 8.5 148 26.9 123 22.4 86 15.6 Number Grade school 5 Some high school 12 High school graduate 36 Some college 35 Undergraduate 19 college degree Some post-graduate 57 10.4 13 Advanced college 62 11.3 15 degree Total 550 100.0% 136 * Did not answer the question regarding education. Did not pay A minimum charge Share of total paid Percent Number Percent (B) Number Percent Index B/A 20.8% 25.5 24.3 28.5 22.1 11 21 74 65 33 4.2 8.1 28.5 25.0 12.7 19 35 112 88 67 79.2% 74.5 75.7 71.5 77.9 95.5 95.3 105.9 111.6 81.4 22.8 24.2 25 28 9.6 10.8 44 47 77.2 75.8 92.3 95.6 24.7% 260 -- 414 75.3% -- TABLE 4-19 FREQUENCY OF PAYMENT OF $.50 MINIMUM FINANCE CHARGE BY EDUCATION LEVEL Non One N # % # % Education Level Grade school 24 19 Some high 47 35 school High school 148112 graduate Some college 12388 Undergraduate 86 67 College degree Some post57 44 graduate Advanced 62 47 college Degree Total 550414 79.21 74.56 Number of months in whichminimum financecharge wasincurred Two Three Four Five Six Seven Eight Nine # % # % # % # % # % # % # % # % 4.2 3 12.84 12.5-8.5 1 -- 1 2.11 4.2 2.1 --- --- --- --- --- -- --- -- -- --- -- --- 75.715 10.110 6.8 6 4.14 2.7 1 0.7 -- -- -- -- -- -- -- -- 71.517 13.810 77.99 10.57 8.1 5 8.1 2 4.12 2.31 1.6 1.2 1 -- 0.8 -- --- --- --- -- --- -- -- --- -- --- 77.29 15.82 3.5 1 1.8-- -- -- -- -- -- -- -- -- -- -- -- 75.89 14.53 4.8 2 3.2-- -- -- -- -- -- 1 1.6-- -- -- -- 7.1 18 3.39 1.6 2 0.4 -- -- 1 0.2-- -- 1 0.2 75.366 12.039 *Omitting three no-answer to the question on education. 60 CHAPTER 5 IMPACT OF THE METHOD OF ASSESSING FINANCE CHARGES The previous chapter analyzed the more important characteristics of revolving account usage as it actually occurred for 865 customers over a 12month period. This chapter will explore the effect of variations in the method of assessing finance charges. It has often been assumed by many that a retailer's choice of a method of finance charge assessment results insubstantial difference in dollar finance charges for customers. Most "evidence," however, has been based on theoretical conjecture of hypothetical cases rather than on empirical data Some of the ambiguity lies in the determination of what is considered substantial." Because of this tendency to use hypothetical examples, one of the main objectives of this study has been to analyze actual account histories over an extended period in order to measure empirically the impact of the method of assessment on the customer's dollar cost of credit. Accordingly, actual data from account records (e.g., beginning balances, amount of purchases and payments, dates of purchases and- payments) were used in a computer simulation of finance charges produced by alternative methods of assessment. Explanations and definitions of each of these methods were explained in Chapter 3. AVERAGE DIFFERENCES IN FINANCE CHARGES Analysis of actual account data and simulations of finance charges under six assessment methods produced average monthly finance charges as shown in Table 5-1. Under the method actually in use during the 12 month period covered by the study (that is, Previous Balance), average monthly dollar finance charges came to $1.24. Other billing methods produced average monthly charges ranging from a low of $1.09 (Adjusted Balance) to a high of $1.47 (True Actuarial Average Daily Balance). To facilitate comparison of the average magnitude of the differences in the average monthly finance charges for one billing method as compared to another, Tables 5-2 (using Mean values)and 5-3 (using Median values) have been prepared. Based on Mean values (that is, the average of all the individual account monthly averages), monthly differences range from zero (Previous Balance as compared to Average Daily Balance Including Debits)to $.38 (Adjusted Balance as compared to True Actuarial Average Daily Balance). Median values indicate about the same range of possible differences. That is, the difference between the median values ranged from $.01 per month for Previous Balance compared to Average Daily Balance Including Debits to $.41 per month for Adjusted Balance compared to True Actuarial Average Daily Balance. Further analysis of the average monthly differences as shown in Tables 5-1, 5-2, and 5-3 indicates that two methods produce equal or lower charges than the Previous Balance method actually used -that is, Adjusted Balance (averaging $.15 a month less) and Average Daily Balance Excluding Debits (averaging $.06 a month less). One method - Average Daily Balance Including Debits - produced the same average monthly charge, based on mean values, as did the Previous Balance. Two methods - Ending Balance (average $.17 a month more) and True Actuarial Average Daily Balance (averaging $.23 a month more) - produced greater charges than did the Previous Balance method. 61 TABLE 5-1 AVERAGE MONTHLY DOLLAR FINANCE CHARGES UNDER SIX DIFFERENT BILLING METHODS, 865 ACCOUNTS Billing Method Mean* Previous Balance Adjusted Balance Ending Balance Average Daily Balance, Including Debits (ADBW) Average Daily Balance, Excluding Debits (ADBX) True Actuarial Average Daily Balance (TADB) Median** $1.24 1.09 1.41 1.24 1.18 1.47 $.31 .25 .62 .30 .28 .66 * The arithmetic mean of the individual monthly averages for all 865 accounts. ** The median of the individual monthly averages for all 865 accounts. In general, the median values shown in Tables 5-1, 5-2, and 5-3 show smaller monthly differences between billing methods than do the mean values. Using mean values, Previous Balance produces an average monthly finance charge some $.15 a month more than Adjusted Balance. However, on the basis of median values, the differences between these two methods amounted to $.06 a month. The main reason for the smaller magnitude of monthly differences resulting from median values is that for a large number of customers, differences resulting from the method of finance charge assessment was zero since these customers avoided finance charges entirely by paying their unpaid balances in full upon receipt of statement. The relative number of customers for which the differences amounted to zero will be evident in many of the tables presented later in this chapter. TABLE 5-2 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, SIX BILLING METHODS, 865 ACCOUNTS (Based on Mean Figures) Billing Method Previous Balance Adjusted Balance Ending Balance Average Daily Balance, Including Debits (ADBW) Average Daily Balance, Excluding Debits (ADBX) True Actuarial Average Daily Balance (TADB) Previous Adjusted Ending Average Daily Average Daily True Actuarial Balance Balance Balance Balance Including Balance Excluding Average Daily Debits Debits Balance -$.15 ($.17) $.00 $.06 ($.23) ($.15) -($.32) ($.15) ($.09) (.38) $.17 $.32 -$.17 $.23 ($.06) $.00 $.15 ($.17) -$.06 ($.23) ($.06) $.09 ($.23) ($.06) -- ($.29) $.23 $.38 $.06 $.23 $.29 -- 62 TABLE 5-3 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, SIX BILLING METHODS, 865 ACCOUNTS (Based on Median Figures) Billing Method Previous Balance Adjusted Balance Ending Balance Average Daily Balance, Including Debits (ADBW) Average Daily Balance, Excluding Debits (ADBX) True Actuarial Average Daily Balance (TADB) Previous Adjusted Ending Average Daily Average Daily True Actuarial Balance Balance Balance Balance Including Balance Excluding Average Daily Debits Debits Balance -$.06 ($.31) $.01 $.03 ($.35) ($.06) -($.37) ($.05) ($.03) ($.41) $.31 $.37 -$.32 $.34 ($.04) ($.01) $.05 ($.32) -$.02 ($.36) ($.03) $.03 ($.34) ($.02) -- ($.38) $.35 $.41 $.04 $.36 $.38 -- Before discussing in greater detail the actual differences resulting from one assessment method as compared to another, it is noteworthy that many of the hypothetical examples used to illustrate the impact on the customer's cost greatly overstate the probable differences that are actually experienced by an "average" customer. In all likelihood, these differences result in no more than about $2 a year—a small sum for most families using revolving credit. DETAILED ANALYSIS OF MONTHLY DIFFERENCES IN DOLLAR FINANCE CHARGES Although the average monthly differences referred to in the section above serve to reflect the most likely impact of the method of finance charge assessment on customer cost, a more detailed analysis is necessary to reveal variations hidden by the use of averages. Accordingly, several of the possible combinations of assessment method are analyzed in depth in the following material. Included in the analysis that follows are various demographic characteristics such as income and education as they relate to the differences which occur. Motivation for analyzing these differences is that frequent allegations claim that certain billing methods take advantage of the poor and unsophisticated" customer.1 The following analysis of monthly differences by demographic characteristics is limited to those differences occurring on the 550accounts for which demographic questionnaires were returned. The distribution of average monthly differences for the 550 accounts is illustrated beside the original distribution for the 865 accounts for each possible combination of billing methods. Examination of these two distributions should prove conclusively that the subsample of 550 accounts for which demographic data were available is very similar to the original sample. 1 Speech by Senator William Proxmire. Congressional Record, (February 20, 1973), S-2806-7. 63 Previous Balance as Compared to Adjusted Balance As indicated earlier, the average cost difference between Previous Balance and Adjusted Balance amounted to $.15 a month or $1.80 a year. Data in Table 5-4 provide a more detailed description of the differences in cost resulting from one method as compared to the other. As shown in Table 5-4, monthly differences between these two billing methods range from zero to $1.86. For almost 40% of the customers, there was no difference in cost (zero difference being defined as either absolute zero or less than one half of one cent difference). Zero difference occurs either when the customer pays his account in full (thereby avoiding finance charges entirely) or when he makes no payment on his account during the month-that is, his "adjusted" balance is identical to his "previous" month's ending balance. For one-half of the customers, the difference amounted to $.04 a month or less (see median value, Table 5-4). The prior discussion of the cost differences between various billing methods referred to the differences occurring between the median monthly charge under one method compared to the median monthly charge under another (see Tables 5-1 and 5-3, for example). At this point, however, the discussion makes use of the actual mean and median cost differences that occurred between one method compared to another. In other words, for each individual account, the difference in cost between one method compared to another was calculated, arrayed, and mean and median values were determined from this distribution of monthly differences. Thus, the mean and median average monthly cost differences (such as shown in Tables 5-4 and following) are not necessarily the same as the difference between the mean and median average monthly finance charge paid (as shown in Tables 5-1, 5-2, and 5-3). TABLE 5-4 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES PREVIOUS BALANCE AS COMPARED TO ADJUSTED BALANCE (Original Sample as Compared to Demographic Survey) Original Sample Demographic survey (865 Accounts) (550 Accounts) Amount of difference* Number Percent Number Percent $.00 342 39.5% 211 38.4% + .01 to .10 181 20.9 114 20.7 + .11 to .15 41 4.7 30 5.5 + .16 to .25 112 12.9 74 13.5 + .26 to .50 125 14.5 83 15.1 + .51 to .75 46 5.3 29 5.3 + .76 to 1.00 14 1.6 6 1.1 +1.01 or more 4 0.5 3 0.5 Total 865 99.9% 550 100.0% Mean (average $.15 $.15 Difference Median difference $.04 $.05 Range of differences $.00 to $1.86 $.00 to $1.86 *When the amount of the difference is a positive value, this indicates that the Previous Balance method is the greater of the two. Source: For the Original Sample, data were taken from a 12-month history of account records. For the Demographic Survey, data were taken from the same source but restricted to account records of those customers responding to the questionnaire. 64 The minimal nature of the differences between these two methods of assessment is indicated not only by the average monthly difference of $.15 and the median difference of $.04, but also by the 60% of the accounts in which the difference in cost amounted to no more than $.10 a month. For over 90% of the customers, the differences amounted to no more than $.50 a month, or $6 for the year. The largest difference for any single customer amounted to $1.86 a month or $22.44 for the 12-month period. Although this may seem significant, it should be noted that this customer maintained an average balance of over $700 a month and would have paid finance charges of over $80 during the year even had the Adjusted Balance method been used. It should also be noted that this customer had a household income of between $15,000 and $20,000, indicating that a cost difference of $22.44 for the year would not be large in relation to his income and level of expenditures. Even though a rather significant difference of $1.86 a month did occur once in 865 accounts, this amount is less than the differences often conjectured in hypothetical examples designed to depict hardships wrought by the Previous Balance method. Thus, although the Adjusted Balance method of assessing finance charges usually produces smaller finance charges than the Previous Balance method, the savings to an individual customer is usually quite minimal. Most hypothetical examples illustrating these two methods, however, consist largely of "horror stories" that vastly overstate the magnitude of the differences involved and usually bear no resemblance whatsoever to what occurs in practice. A rather common example of such "horror stories" involves a hypothetical customer who has a balance of $100 on his account to which he applies a payment of $90. Under the Previous Balance system he is charged a finance charge based on the beginning balance of $100, whereas under an Adjusted Balance method, he would have been charged on the $10 balance remaining after his payment. Thus the point is made that the customer "pays 10 times the amount of interest they otherwise would have paid if the creditor charged against the closing balance."2 To imply that customers can be expected usually to pay anything near "ten times" more under a Previous Balance system is contrary to available empirical data. It is noteworthy, however, that although the impact on an individual consumer is usually small, a store's total revenue from finance charges can be substantially affected by choice of assessment method. This point will be discussed in greater detail later in this chapter, but data provided by the accounts sampled in this study indicate that use of the Adjusted Balance method produced some 12% less finance charge revenue for the year than Previous Balance. Differences in Cost as Related to Income As indicated earlier, one of the concerns frequently voiced with regard to the use of some particular methods of assessing finance charges is that the poor and unsophisticated consumer is victimized or treated unfairly under some billing methods. In order to determine if the differences in cost between various billing methods impacted more heavily on lower income and the less educated individuals, certain demographic information was related to the cost differences experienced by each customer. Table 5-5 illustrates the distribution of the differences in average monthly finance charges under the Previous Balances system as compared to Adjusted Balance, classified by household income group. Data in this table indicate some small variation in the amount of the monthly difference among various income groups. Whereas the average monthly difference for the total sample amounted to $15, for various income groups, average monthly differences range from $.09 (for incomes of $7,501 to $10,000) to $17 (for incomes of 2 Id., S-2806. 65 $10,001 to $15,000). Thus, although there is some variation among income groups, it would not appear to be large. The most important point from these data is that it is not the lower income groups ($10,000 or less) that experience the largest dollar cost difference between these two methods. The two income groups of $10,000 or less had average monthly cost differences of $.12 and $.09—less than any of the other groups and below the $.15 a month average difference for the total sample. Therefore, the lower income groups are not affected more than other levels of income by use of the Previous Balance system. In fact, if a creditor were to shift from Previous Balance to Adjusted Balance, lower income groups would experience less of a gain than other income levels (that is, the smaller the average monthly difference in cost the less the advantage from a change in billing method). This point is reinforced by data to be discussed in greater detail below. TABLE 5-5 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO ADJUSTED BALANCE BY HOUSE INCOME GROUPS Amount of Difference* Total Sample (N = 550) $.00 .01 to .10 .11 to .15 .16 to .25 .26 to .50 .51 to .75 .76 to 1.00 1.01 or more Mean Difference Median Difference 38.4% 20.7 5.5 13.5 15.1 5.3 1.1 0.5 $.15 $.05 Household Income** $7,500 or $7,501- $10,001- $15,001- $20,001- $25,000less ($10,000 15,000 20,000 25,000 or more (N=52) (N=54) (N=146) (N=129) (N=69) (N=38) 38.5% 42.6% 23.3% 34.1% 47.8% 55.7% 23.1 20.4 28.1 20.2 15.9 12.5 7.7 9.3 4.1 5.4 5.8 3.4 17.3 13.0 18.5 14.7 7.2 8.0 3.8 14.8 18.5 19.4 15.9 11.4 9.6 -4.8 5.4 7.2 5.7 --2.7 --1.1 ---0.8 -2.3 $.12 $.09 $.17 $.16 $.13 $.15 $.045 $.03 $.10 $.08 $.02 $.00 * When the amount of the difference is a positive value, this indicates that the Previous Balance is the greater of the two. ** Omitting 12 respondents that did not answer the question concerning income. Index data in Table 5-6 also indicate that lower income groups do not feel the impact of the difference between Previous Balance and Adjusted Balance more heavily than do other groups. The Index values shown compare the relative share of the total difference experienced by all 500 accounts with the proportionate part of the sample for each income group. For example, families with incomes of $7,500 or less accounted for 8.2% of the total difference (that is, $79.44 out of a total difference for all accounts of $973.56). When this figure (8.2%) is related to the percentage of the total sample in the income group of $7,500 or less (9.5%), the result is an Index value of 86.3. Index values of less than 100 indicate that a group's share of the total dollar difference is less than its relative magnitude compared to the total sample. Thus, when the Index value is less than 100, it can be stated 66 that the cost differences produced by use of one billing method as compared to another has less than a proportionate impact on that group. TABLE 5-6 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO ADJUSTED BALANCE Share of Total Dollar Difference by Income Groups Household Income N Percent of Total Average Percent of Total sample Difference Monthly Total difference (A) By group Difference (B) $7,500 or less 52 9.5 $79.44 $.12 8.2% 7,501-10,000 54 9.8 61.56 .09 6.3 10,001-15,000 146 26.5 299.76 .17 30.8 15,001-20,000 129 23.5 247.08 .16 25.4 20,001-25,000 69 12.5 110.64 .13 11.4 25,001 or more 88 16.0 161.28 .15 16.6 Total 538* 97.8%* $973.56 $.15 98.6%* Index B/A 86.3 64.3 116.2 108.1 91.2 103.8 --- *Omitting 12 respondents that did not answer the question regarding income. Since the Index values for both groups with incomes of $10,000 or less is less than 100, this further supports the statement made earlier that lower income groups are not affected more than other income levels by use of the Previous Balance system. Likewise, a shift from Previous Balance to Adjusted Balance would result in less gain for lower income levels than for other higher income groups. The largest gains from such a shift would be families with incomes of $10,001 to $15,000 (Index value of 116.2). The essential conclusion here is that, while all income classes would pay lower finance charges under an Adjusted Balance system, middle-income customers would benefit much more than low-income families. Differences in Cost Related to Education Level Data in Table 5-7 show the distribution of average monthly cost differences for all 550 accounts by level of education. As in the case of income, some variation exists in the magnitude of the differences. Such variations are relatively insignificant, however, ranging from $.13 to $.18, compared to an average monthly difference of $.15 for the total sample. Index values in Table 5-8 also point to the insignificant cost differences among levels of education. The most important point to be observed from these data is that it is not the lower levels of education where the monthly cost differences are greatest ($.14 a month for High School Graduates or less as compared to $.16 a month for Some College and $.18 for Advanced College Degree). This indicates that the impact of one billing method compared to another is not greater on those families with less education; and if a creditor were to shift from Previous Balance to Adjusted Balance, lower levels of education would experience less of a gain. Previous Balance as Compared to Average Daily Balance Including Debits (ADBW) Although the Previous Balance and Adjusted Balance methods of assessing finance charges on revolving credit accounts have been the most widely used since the 1950s, several types of Average Daily Balance (ADB) systems have been appearing with increasing frequency. 67 In this section, analysis of the cost differences between the Previous Balance system and Average Daily Balance Including Debits (hereafter referred to as ADBW) is made. Briefly, an ADBW system bases finance charges on the average daily balance in the account during the billing period unless the previous month's balance is paid in full or unless the billing period began with a zero account balance (see Chapter 3 for a more complete definition of terms). These two methods produce very nearly the same level of finance charges for a typical revolving credit customer, As indicated earlier, the difference between the mean and median figures for both methods was near zero. Both methods produced average monthly dollar finance charges of $1.24, when rounded to the nearest cent. As indicated by the mean difference figure in Table 5-10, the actual difference amounts to slightly over one-half cent. Additional data in Table 5-9 provide a more thorough picture of the cost differences between Previous Balance and ADBW than does references to 11 “average” differences. The generally minimal cost differences between these two methods are readily indicated. For example, for over 40% of the customers the cost difference was zero (that is, absolute zero or a difference of less than one-half cent). For approximately 87% of the families, the difference in cost amounted to no more than $10 a month. A comparison of Previous Balance with ADBW is noteworthy in that one method may be more expensive for one customer and less expensive for another, depending upon their purchase and payment patterns. Further analysis of data in Table 5-9 indicates that for approximately 30%(268) of the customers, the Previous Balance method resulted in a greater cost than would have ADBW. On the other hand, for some 26% (228) of the customers it cost less than ADBW. If analysis is confined to the positive values shown in Table 5-9 (that is, instances where Previous Balance is more costly than ADBW), the average monthly difference amounts to $.06. Confining the analysis to negative values (where ADBW costs more), the average monthly difference amounted to $.09. TABLE 5-7 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO ADJUSTED BALANCE BY EDUCATION LEVEL Amount of Difference* Total Grade Sample School (N=550) (N=24) Some High Some Undergraduate Some Advanced High School College College PostCollege School Graduate (N=123) Degree Graduate Degree (N=47) (N=148) (N=86) (N=57) (N=62) 36.2% 29.7% 36.6% 50.0% 47.4% 43.5% 21.3 25.0 20.3 20.9 15.8 16.1 6.4 6.8 5.7 3.5 3.5 4.8 19.1 18.2 14.6 9.3 7.0 8.1 17.0 16.2 13.8 8.1 21.1 14.5 -3.4 8.1 5.8 5.3 6.5 2.1 0.7 0.8 1.2 -3.5 ---1.2 -3.2 $.14 $.14 $.16 $.13 $.14 $.18 $.00 38.4% 33.3% $.01 to .10 20.7 20.8 $.11 to .15 5.5 8.3 $.16 to .25 13.5 12.5 $.26 to .50 12.5 20.8 $.51 to .75 5.3 4.2 .76 to 1.00 1.1 -$1.01 or more 0.5 -Mean $.15 $.14 Difference Median $.05 $.075 $.05 $.065 $.06 $.005 $.01 $.03 Difference * When the amount of the difference is a positive value, this indicates that the Previous Balance method is the greater of the two. ** Three no answers to the question concerning education omitted. 68 TABLE 5-8 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO ADJUSTED BALANCE Share of Total Dollar Difference by Education Level Education N Grade school 24 Some high 47 School High school 148 Graduate Some college 123 Undergraduate 86 College degree Some post57 Graduate Advanced college 62 Degree Total 547* Percent of Total Average Percent of Index Total sample Difference Monthly Total difference B / A (A) By group Difference (B) 4.4 $40.92 $.14 4.2 95.5 8.5 77.88 .14 8.0 94.1 26.9 247.44 .14 25.4 94.4 22.4 15.6 228.96 139.20 .16 .13 23.5 14.3 104.9 91.7 10.4 95.28 .14 9.8 94.2 11.3 131.52 .18 13.5 119.5 99.5%* $973.56 $.15 98.7%* --- * Omitting three respondents that did not answer the question regarding education. Thus, although the Previous Balance system produces a higher cost than ADBW a greater percentage of the time, the impact on the customer is not as great as when ADBW costs more (that is, $.06 a month more on the average when Previous Balance is more expensive as compared to $.09 a month when ADBW is greater). These figures are, however, sufficiently close that they may be statistically insignificant from one another. The most important factor in this difference is the stability of the number of days from purchase to billing date and the number of days from billing date to payment date. These differences will stay small only so long as the distribution of these two periods have a mean of approximately one-half month each (or one month in sum), Alternately, the differences may be affected by large and sustained growth (or decline) in average balance size. A monotonic trend in excess or deficiency of purchases over payments would alter these differences independently of timing. Thus the foregoing conclusions depend greatly on an assumption of constancy in consumer economic behavior regardless of method of finance charge assessment. Differences in Cost as Related to Income Concern has often been expressed as to whether or not income groups feel a different impact because of a change in assessment method. Comparisons between income data and monthly cost differences aid in making such a determination. In analyzing the effect of a Previous Balance system compared to an ADBW system, it is helpful to consider two distinct areas: (1) the frequency with which one system may be more costly than the other and (2) the total dollar impact of cost differences between systems. 69 TABLE 5-9 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) (Original Sample as Compared to Demographic Survey) Amount of difference* -.51 or less -.26 to -.50 -.16 to -.25 -.11 to -.15 -.01 to -.10 $.00 +.01 to .10 +.11 to .15 +.16 to .25 +.26 or more Total Positive values Negative values Mean difference, all Accounts Median difference, all Accounts Range of differences Mean difference, positive Values only Median difference, positive Values only Mean difference, negative Values only Median difference, negative Values only Original sample Demographic survey (865 Accounts) (550 Accounts) Number Percent Number Percent 2 0.231 1 0.2 16 1.850 9 1.6 21 2.428 11 2.0 26 3.006 20 3.6 163 18.844 107 19.5 369 42.659 227 41.3 222 25.665 143 26.0 25 2.890 18 3.3 12 1.387 11 2.0 9 1.040 3 0.5 865 100.000 550 100.0 268 30.98% 175 31.8% 228 26.36% 148 26.9% -$.0052 -$.0039 $.00 $.00 -$.59 to $.45 $.06 -$.53 to $.39 $.06 $.04 $.04 -$.09 -$.09 -$.06 -$.065 * Where the amount of the difference is a positive value, Previous Balance is the greater of the two. Source: For the Original Sample, data were taken from a 12-month history of account records. For the Demographic Survey, data were taken from the same source but restricted to account records of those customers responding to the questionnaire. It was shown in Table 5-9 that some customers paid greater finance charges under the Previous Balance system than under ADBW, whereas others would have paid more under ADBW. Data in Table 5-10 indicate for each income level the percentage of families in which Previous Balance costs more than ADBW, the percentage in which ADBW costs more than Previous Balance, and the percentage in which there is no difference in cost. As mentioned earlier, Previous Balance was the more expensive of the two systems (when there was a difference) by a count of 175 (31.8% of sample) to 148 (26.9% of sample). Data in Table 5-10 show that when there is a difference, the tendency for Previous Balance to cost more is true for all but two income groups-$10,001 to $15,000 and $25,001 or more. For families with incomes of $20,000 or less, the tendency for 70 Previous Balance to cost more is greater (32.9 to 38.9%) than for the sample as a whole (31.8%). The reverse is true among families with incomes of more than $20,000. For most income levels the tendency for ADBW to cost more than Previous Balance was about the same frequency as the total sample (26.9%). Only two income groups ($7,501 to $10,000 with 14.8% and $10,001 to $15,000 with 34.2%) varied from the overall sample results to any significant degree. The above discussion has centered on the frequency or likelihood of Previous Balance costing more than ADBW or vice versa. Data in Table 5-11 provide insight into the dollar impact or magnitude of the cost differences between Previous Balance and ADBW by income level. As indicated, the mean and median cost difference for the total sample was zero. By income level, mean differences vary insignificantly, ranging from -$.01 to $.01; median differences are zero for all income groups. The similarity of these data by income levels fails to support the proposition that any one income group is affected more than another in terms of total dollar impact. When Previous Balance exceeds ADBW- Previous Balance costs more than ADBW for a total of 175 customers (or 31.8%) out of the 550 responding to the demographic questionnaire. For these 175 customers, data in Table 512 indicate for each income level (1) the group's percentage of the total difference in finance charges, (2) the group's proportion of the total sample, and (3) an Index value relating (2) to (1). TABLE 5-10 RELATIVE IMPACT ON CUSTOMER FINANCE CHARGES UNDER PREVIOUS BALANCE AS COMPARED TO AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) BY INCOME GROUP Previous Balance Greater than ADBW Household N Income $7,500 or less 52 $7,501-10,000 54 $10,001-15,000 146 $15,001-20,000 129 $20,001-25,000 69 $25,001 or more 88 No answer 12 Total 550 ADBW greater than Previous Balance Previous Balance equal to ADBW Number Percent Number Percent Number Percent 19 21 48 46 20 18 3 175 36.5 38.9 32.9 35.7 29.0 20.5 0.5 31.8% 13 8 50 37 17 22 1 148 25.0 14.8 34.2 28.7 24.6 25.0 0.2 26.9% 20 25 48 46 32 48 8 227 38.5 46.3 32.9 35.7 46.4 54.5 1.5 41.3% 71 TABLE 5-11 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) BY HOUSEHOLD INCOME GROUPS Amount of Difference* Total Sample (N = 550) -$.51 or less -.26 to -.50 -.16 to -.25 -.11 to -.15 -.01 to -.10 $.00 $.01 to .10 .11 to .15 .16 to .25 .26 or more Mean difference Median difference 0.2% 1.6 2.0 3.6 19.5 41.3 26.0 3.3 2.0 0.5 $.00 $.00 Household Income** $7,500 or $7,501- $10,001- $15,001- $20,001- $25,000less ($10,000 15,000 20,000 25,000 or more (N=52) (N=54) (N=146) (N=129) (N=69) (N=38) ---0.8% --3.8% -2.1% -2.9% 2.3% -1.9% 1.4 3.1 5.8 --1.9 2.7 3.1 2.9 9.1 21.2 11.1 28.1 21.7 13.0 13.6 38.5 46.3 32.9 35.7 46.4 54.5 28.8 35.2 28.8 26.4 23.2 15.9 5.8 3.7 1.4 5.4 2.9 2.3 1.9 -2.1 3.1 1.4 2.3 --0.7 0.8 1.4 -$.00 $.01 $-.01 $.00 $-.01 $-.01 $.00 $.00 $.00 $.00 $.00 $.00 *When the amount of the difference is a positive value, this indicates that the Previous Balance method is the greater of the two. ** Twelve no-answers to the income question omitted. Index values of less than 100 indicate that an income group accounted for less than its relative share of the total dollar difference-that is, the impact on these groups of the cost difference between Previous Balance and ADBW would be less than on groups where the Index value exceeds 100. These data show that all of the income groups with $15,000 or less annual income had index values of less than 100. Higher income levels had Index values of more than 100. Thus, if the choice of billing method has a heavy impact on certain income groups, it would be on the upper-income families rather than lower-income families. By the same reasoning, if a creditor changed from Previous Balance to ADBW, families with higher incomes would benefit to a greater degree than would those with middle and lower incomes. When ADBW exceeds Previous Balance: Use of an ADBW system of computing finance charges would have produced greater finance charges than Previous Balance for 148 customers out of the 550 responding to the demographic questionnaires. For these customers, data showing the relative impact of the cost differences by income group is provided in Table 513. As can be observed, all income groups of $20,000 or less had an Index value of under 100, indicating that their relative share of the total difference in finance charges between Previous Balance and ADBW is less than that of higher income levels. Thus, the impact of the cost difference between these two methods falls more heavily on higher-income families, and it is these customers who would stand to benefit most from a change in billing method from ADBW to Previous Balance. 72 TABLE 5-12 AVERAGE MONTHLY DIFFERENCE IN DOLLAR FINANCE CHARGES, WHERE PREVIOUS BALANCE EXCEEDED AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) (175 Accounts) Share of Total Dollar Difference by Income Group Household Income N Percent of Total Average Percent of Total sample Difference Monthly Total difference (A) By group Difference (B) $7,500 or less 19 10.9 $1.03 .054 9.5 $7,501-10,000 21 12.0 1.10 .052 10.2 10,001-15,000 48 27.4 2.80 .058 25.9 15,001-20,000 46 26.3 3.17 .069 29.3 20,001-25,000 20 11.4 1.40 .070 12.9 25,001 or more 18 10.3 1.24 .069 11.5 Total 172 98.3* $10.82 $.062 99.27%* Index B/A 87.2 85.0 94.5 111.4 113.2 111.7 --- * Omitting three respondents that did not answer the income question. TABLE 5-13 AVERAGE MONTHLY DIFFERENCE IN DOLLAR FINANCE CHARGES, WHERE AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) EXCEEDED PREVIOUS BALANCE (148 Accounts) Share of Total Dollar Difference by Income Group Household Income N Percent of Total Average Percent of Index Total sample Difference Monthly Total difference B / A (A) By group Difference (B) $7,500 or less 13 8.8 $0.98 $.075 7.6 86.4 $7,501-10,000 8 5.4 0.60 .075 4.6 85.2 10,001-15,000 50 33.8 3.88 .78 29.9 88.5 15,001-20,000 37 25.0 3.22 .087 24.8 99.2 20,001-25,000 17 11.5 1.90 .112 14.7 127.8 25,001 or more 22 14.9 2.25 .102 17.4 116.8 Total 147* 99.3* $12.97 $.087 98.9%* --* Omitting one respondent that did not answer the income question. 73 Differences in Cost as Related to Level of Education To determine if there is a difference in the effect of Previous Balance compared to an ADBW system on families with different degrees of educational attainment, it is helpful to consider both the frequency with which one system is more costly than the other and the total dollar impact of the cost differences. Data in Table 5-14 show that for all levels of education except one (Some Post-Graduate) finance charges under a Previous Balance system exceed those under ADBW. Previous Balance was the more costly for the largest percentage (41.7%) of families in the Grade School level, but the relatively small cell size (N=24) may tend to reduce the reliability of the data as predictive of a population generally. For other education groups where Previous Balance was more costly, the percentage was not greatly different from that of the total sample (31.8%). Evidence of the total dollar impact or the magnitude of the cost differences between Previous Balance and ADBW by education level is provided by the distribution of the monthly dollar cost differences shown in Table 5-15. From these data it can be observed that for all customers combined, the mean and the median monthly cost differences are zero. Among education groups, mean cost differences differ very little, ranging from -$.02 to $.02; median cost differences are zero for all education levels. The two largest cost differences occurred at the two extremes. For those families in the Grade School level, ADBW was more expensive by an average of $.02 a month; whereas for customers in the Advanced College Degree category, Previous Balance was more costly by an average of $.02 a month. The size of these monthly cost differences, however, are so small that it is doubtful whether there is any statistical significance to the differences. Thus, as to total dollar impact the data do not seem to support the proposition that certain education levels are affected more than others by use of Previous Balance as compared to ADBW. TABLE 5-14 RELATIVE IMPACT ON CUSTOMER FINANCE CHARGES UNDER PREVIOUS BALANCE COMPARED TO AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) BY EDUCATION GROUP Previous Balance Greater than ADBW Education N Grade school 24 Some high school 47 High school 148 Graduate Some college 123 Undergraduate 86 College degree Some post57 Graduate Advanced college 62 Degree No answer 3 Total 550 ADBW greater than Previous Balance Previous Balance equal to ADBW Number 10 15 54 Percent 41.7 31.9 36.5 Number 6 14 44 Percent 25.0 29.7 29.7 Number 8 18 50 Percent 33.3 38.3 33.8 41 23 33.3 26.8 33 18 26.8 20.9 49 45 39.8 52.3 9 15.8 17 29.8 31 54.4 21 33.9 15 24.2 26 41.9 2 175 66.7 31.8% 1 148 33.3 26.9% 0 227 0 41.3% 74 When Previous Balance exceeds ADBW: For those 175 families in which Previous Balance was more costly than ADBW, data in Table 5-16 show the relative dollar impact of the monthly cost differences by education level. For all but three groups, Index values are less than 100, indicating a less than proportionate share of the total dollar cost differences that resulted between the two billing methods. Two of the groups with Index values greater than 100 (indicating a greater than proportionate share of the cost differences) were at the highest levels of educational attainment. It was mentioned earlier that the monthly cost differences between Previous Balance and ADBW were minimal but data in Table 5-16 tend to indicate that the differences that do result impact somewhat more heavily on higher levels of education. Thus, it is these higher education groups that would stand to benefit (or lose) most if a creditor were to change from Previous Balance to ADBW or vice versa. It should be noted, however, that the number of observations on which these data are based is quite small (i.e., nine in Some Post-Graduate, ten in Grade School), limiting its significance. When ADBW exceeds Previous Balance: For some 148 customers use of an ADBW system would have resulted in greater finance charges than the Previous Balance method. Data in Table 5-17 show by education level the total dollar impact of the cost differences. These data indicate a rather erratic pattern. The Grade School group has the largest Index value (170.7), but other levels with values greater than 100 are much higher in terms of educational attainment. Likewise, the two groups with the lowest Index values (65.3 and 70.5) are at opposite ends of the education scale. Because of the extremely small number of observations (i.e., six in Grade School group), definitive statements concerning the relationship of educational attainment to monthly cost differences when ADBW exceeds Previous Balance are not warranted. Previous Balance vs. ADBW - Summary Analysis of the impact of using Previous Balance as compared to ADBW is complicated considerably by the fact that one of the two methods can, depending upon customer purchase and payment patterns, cost more than the other and vice versa. It can be said, however, that Previous Balance is likely to cost more for a greater number of customers, particularly for those with incomes of $20,000 or less. In terms of total dollar cost difference, however, the differences are usually minimal (one or two cents a month). In this regard, it should be noted that the dollar impact of cost differences does not fall more heavily on families with lower incomes (although as noted earlier for lower-income families it may be more common for Previous Balance to exceed ADBW). Previous Balance as Compared to Average Daily Balance Excluding Debits (ADBX) Another type of average daily balance system of current interest is one in which the finance charge is based upon an average daily balance from which current month's purchases have been excluded (see Chapter 3 for complete description). It is the exclusion of current month's purchases which distinguishes the Average Daily Balance Excluding Debits system (hereafter referred to as ADBX) from the ADBW system discussed above. 75 TABLE 5-15 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO AVERAGE DAILY BALANCE INCLUDING DEBITS (ABDW) BY LEVEL OF EDUCATION Of Education* Some High Some Undergraduate Some Advanced High School College College PostCollege School Graduate (N=123) Degree Graduate Degree (N=47) (N=148) (N=86) (N=57) (N=62) $-.51 or less 0.2% ---0.8% ----.26 to -.50 1.6 8.3% -0.7% 1.6 3.5% 1.8% --.16 to -.25 2.0 -2.1% 2.7% 1.6 1.2 5.3 --.11 to -.15 3.6 4.2 2.1 2.7 4.9 4.7 1.8 4.8 -.01 to -.10 19.5 12.5 25.5 23.6 17.9 11.6 21.1 19.4 $.00 41.3 33.3 38.3 33.8 39.8 52.3 54.4 41.9 $.01 to .10 26.0 33.3 27.7 30.4 30.1 23.3 10.5 21.0 .11 to .15 3.3 4.2 -4.7 2.4 1.2 3.5 4.8 .16 to .25 2.0 4.2 2.1 1.4 0.8 2.3 -6.5 .26 or more 0.5 -2.1 ---1.8 1.6 Mean difference $.00 -$.02 $.01 $.00 -$.01 -$.01 -$.01 $.02 Median difference $.00 $.00 $.00 $.00 $.00 $.00 $.00 $.00 * When the amount of the difference is a positive value, Previous Balance is the greater of the two. ** Omitting three respondents that did not answer the question regarding education. Amount of Difference* Level Total Grade Sample School (N=550) (N=24) TABLE 5-16 AVERAGE MONTHLY DIFFERENCE IN DOLLAR FINANCE CHARGES, WHERE PREVIOUS BALANCE EXCEEDED AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) (175 Accounts) Share of Total Dollar Difference by Education Level Education N Grade school 10 Some high 15 School High school 54 Graduate Some college 41 Undergraduate 23 College degree Some post9 Graduate Advanced college 21 Degree Total 173* Percent of Total Average Percent of Index Total sample Difference Monthly Total difference B / A (A) By group Difference (B) 5.7 $.54 $.054 5.0% 87.7 8.6 1.12 .075 10.4 120.9 30.9 2.81 .052 26.0 84.1 23.4 13.1 2.15 1.26 .052 .055 19.9 11.6 85.0 88.5 5.1 .95 .106 8.8 172.5 12.0 1.83 .087 16.9 140.8 98.8%* 110.82 $.06 98.5% --- * Omitting two respondents that did not answer the question regarding education. 76 Finance charges assessed under an ADBX system will always be less than or equal to those assessed under Previous Balance. Some critics of this method have claimed that since customers do not pay their accounts much earlier than absolutely necessary, finance charge savings from early payment are unlikely to be often realized. Thus it is said that the ADBX system is not really a meaningful option.3 Analysis of the data shown in Table 5-18 indicates clearly, however, that a great majority of customers (50%) actually pay less under this form of average daily balance ($.06 a month on the average) as compared to Previous Balance. One reason for the savings under ADBX may be, as indicated earlier in Table 4-1, that customers usually do not wait until the last possible moment in which to make their payments, but rather tend to pay on their accounts around the middle of the month following the billing date. It is true that the cost differences between these Previous Balance and ADBX systems as applied to an individual account is not very striking, but the same observation is just as appropriate when comparing Previous Balance to almost any other billing method with the exception of a True Actuarial Average Daily Balance method. In the latter instance, the cost differences are frequently sizable. A complete picture of the cost differences between Previous Balance and ADBX is provided by the distribution in Table 5-18. It is evident from these data that the differences in monthly costs under these two methods are almost always small. For over 40% of the accounts, the difference was zero, largely because payment of balances in full results in no finance charges under either method. For another 38%, differences amounted to no more than $10 a month. Thus, for almost four out of every five customers, the monthly cost differences amounted to no more than $1.20 for the entire year. In only seven instances did the average cost difference exceed $.25 a month, or $3 for the year. The largest difference in cost for an individual account was $.73 a month, or $8.76 for the year. This customer paid $23.28 in finance charges during the year under the Previous Balance system. Under an ADBX system his finance charges for the year would have been $14.56. TABLE 5-17 AVERAGE MONTHLY DIFFERENCE IN DOLLAR FINANCE CHARGES, WHERE AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) EXCEEDED PREVIOUS BALANCE (148 Accounts) Share of Total Dollar Difference by Education Level Education N Percent of Total Average Percent of Index Total sample Difference Monthly Total difference B / A (A) By group Difference (B) 4.1 $.91 $.152 7.0% 170.7 9.5 .87 .062 6.7 70.5 Grade school 6 Some high 14 School High school 44 29.7 3.23 .073 24.9 Graduate Some college 33 22.3 3.15 .095 24.3 Undergraduate 18 12.2 2.21 .123 17.0 College degree Some post17 11.5 1.68 .099 13.0 Graduate Advanced college 15 10.1 .85 .057 6.6 Degree Total 147* 99.4%* 12.97 -$.09 99.5%* * Omitting one respondent that did not answer the question regarding education. 3 Id. S-2807. 77 83.8 109.0 139.3 113.0 65.3 --- Differences in Cost as Related to Income To determine if the relative impact of the cost differences between Previous Balance and ADBX varied with income level, the monthly differences were distributed according to income group as shown inTable519. The mean difference displays little variation among income groups, ranging from $.04 to $.07 a month, compared to an average of $.06 for the total sample. Likewise, there exists minimal variation in the median differences which range from zero to $.04 a month, compared to an average of $.02 for the entire sample. Data in this table indicate, however, that families with incomes of more than $25,000 display an incidence of zero differences between the two billing methods in substantially greater numbers (58% as compared to 40% for the total sample). The same is true to a lesser extent in families in the $20,001 to $25,000 bracket (49% zero values). TABLE 5-18 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO AVERAGE DAILY BALANCE, EXCLUDING DEBITS (ADBX) (Original Sample as Compared to Demographic Survey) Original sample Demographic survey (865 Accounts) (550 Accounts) Amount of difference* Number Percent Number Percent $.00 358 41.387% 222 40.364% +.01 to .10 326 37.688 209 38.000 +.11 to .15 68 7.861 44 8.000 +.16 to .25 68 7.861 46 8.364 +.26 to .50 38 4.393 27 4.909 +.51 to .73 7 .809 2 .364 Total 865 99.999% 550 100.001% Mean (Average) $.06 $.06 Difference Median difference $.02 $.02 Range of differences $.00 to $.73 $.00 to $.55 * When the amount of the difference is a positive value, this indicates that the Previous Balance method is the greater of the two. Source: For the Original Sample, data were taken from a 1 2-month history of account records. For the Demographic Survey, data were taken from same source but restricted to account records of those customers responding to the questionnaire. On the other hand, families with incomes exceeding $25,000 incur cost differences between Previous Balance and ADBX of greater magnitude much more often than other income groups. This is indicated by the fact that 11.3% of families in that group incurred monthly differences of $.26 or more, whereas only 5.3% of the total sample experienced differences of that magnitude. Additional data describing the impact of the cost differences between Previous Balance and ADBX are provided by Table 5-20. As in previous comparisons, an Index value is used relating the total difference paid by each income group to its proportion of the total sample. As shown by these data, three income groups account for a smaller than relative share of the total difference incurred. These include families with incomes of $10,000 78 or less (two groups) and $20,001 to $25,000. The two middle income groups (with Index values of 110.9 and 114.5) account for more than their proportionate share of the total dollar difference. The highest income group (more than $25,000) had differences equal to their proportion as indicated by an Index value of 100. The fact that 58% of the families in this highest level of income had zero differences probably accounts for the fact that their Index was not over 100. TABLE 5-19 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) BY HOUSEHOLD INCOME GROUPS Amount of Difference* Total Sample (N = 550) $.00 +.01 to .10 +.11 to .15 +.16 to .25 +.26 to .50 +.51 to .73 Mean difference Median difference 40.4% 38.0 8.0 8.4 4.9 0.4 $.06 $.02 Household Income** $7,500 or $7,501- $10,001- $15,001- $20,001- $25,000less ($10,000 15,000 20,000 25,000 or more (N=52) (N=54) (N=146) (N=129) (N=69) (N=38) 38.5% 42.6% 27.4% 35.7% 49.3% 58.0% 46.2 40.7 45.9 39.5 31.9 21.6 3.8 11.1 11.0 8.5 5.8 5.7 5.8 5.6 12.3 10.1 8.7 3.4 5.8 -2.1 6.2 4.3 10.2 --0.7 --1.1 $.05 $.04 $.07 $.07 $.05 $.06 $.02 $.01 $.04 $.04 $.01 $.00 * When the amount of the difference is a positive value, this indicates that Previous Balance is the greater of the two. ** Omitting 12 respondents that did not answer the question concerning income. TABLE 5-20 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) Share of Total Dollar Difference by Income Groups Household Income N Percent of Total Average Percent of Total sample Difference Monthly Total difference (A) By group Difference (B) $7,500 or less 52 9.5 $33.36 $.05 8.1 $7,501-10,000 54 9.8 27.60 .04 6.7 10,001-15,000 146 26.5 120.84 .07 29.4 15,001-20,000 129 23.5 110.52 .07 26.9 20,001-25,000 69 12.5 45.24 .05 11.0 25,001 or more 88 16.0 65.52 .06 16.0 Total 538* 97.8* $410.76 $.06 98.1* Index B/A 85.3 68.4 110.9 114.5 88.0 100.0 --- * Omitting respondents that did not answer the income question. Thus it is evident that the impact of the cost differences between Previous Balance and AD BX is greatest on middle-income families and least on lower-income customers. Therefore, a change from Previous Balance to ADBX will result in the greatest savings to middle-income families and the smallest relative gain for lower-income families. 79 Differences in Cost as Related to Education Data relating the cost differences between Previous Balance and ADBX to education level are provided in Table 5-21, First, the frequently small differences by education level are indicated by the mean differences shown in this table. These range from $.05 to $.07 a month compared to $.06 for the entire sample. Median differences also show a similar minimal variation with amounts ranging from $.01 to $.03 a month, compared to $.02 a month for the total sample. Thus, variation by education level is even smaller than that by income level. Some differences can be noted between the lowest level of education (Grade School) and higher levels. For example, as shown in Table 5-21, families with Grade School education compared to other groups were less likely to have zero differences (33.3%) and more likely to have differences ranging from $.01 to $15 a month. On the other hand, the Grade School group, as compared to other levels, was less likely to have the largest monthly differences, that is, more than $.15 a month. The overall dollar impact of the cost differences as related to education level is best indicated by data in Table 5-22. There is little variation in the relative impact among education levels as indicated by the fact that for five of the first six levels of education, the Index values range from 97.6 to 105.8. The dollar impact was least on the Undergraduate College Degree group, with an Index of 77.6; the impact was greatest among families with an Advanced College Degree where the Index value was 119.5. Thus, the data do not give support to the proposition that the cost differences between Previous Balance and ADBX fall most heavily on unsophisticated families (with education level identifying the degree of sophistication). Cost variation according to education is small, but if the impact is greater on any one group, it is on families where the head of the household has an advanced degree. Therefore, if a creditor were to change from Previous Balance to ADBX, there would be little discernible impact on any one education group, but the greatest gain would be experienced by those families with the highest educational attainment. Previous Balance as Compared to True Actuarial Average Daily Balance Another variation in methods of assessing finance charges on revolving credit accounts is the True Actuarial Average Daily Balance system (hereafter referred to as TADB). This is a method that is rarely used in the retail industry because of the complete absence of so-called "free time." That is, there is a finance charge under the TAD13 system for any billing period in which there is balance activity regardless of whether or not the period began with a zero balance or whether the previous month's ending balance was paid in full. Thus, customers do not have the privilege of using their accounts on a 30-day charge basis with no finance charge as is true with virtually all other billing systems. A TADB system usually results in greater finance charges over a period of time than any other method of assessing charges, primarily because of the inability of avoiding finance charges through payment of ending balances in full. Data in Table 5-23 show clearly the magnitude of the differences in monthly charges under Previous Balance as compared to TADB. As can be observed from these data, Previous Balance was less expensive for 761 accounts or almost 88% of the time with an average monthly difference of $.23. In addition to the large number of accounts for which the cost difference was zero, another 26% of the customers had monthly differences amounting to no more than $.10 a month, or $1.20 a year. Average monthly cost differences amounted to more than $.10 a month for less than 25% of the accounts. The absolute range of cost differences was from $.00 to $.89, with an average monthly difference for all accounts of $.07. 80 TABLE 5-21 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) BY EDUCATION LEVEL Level Total Grade Sample School (N=550) (N=24) Amount of Difference* $.00 +.01 to .10 +.11 to .15 +.16 to .25 +.26 to .50 +.51 to .73 Mean difference Median difference 40.4% 38.0 8.0 8.4 4.9 0.4 $.06 $.02 33.3% 45.8 12.5 4.2 4.2 -$.06 $.015 Of Education** Some High Some Undergraduate Some Advanced High School College College PostCollege School Graduate (N=123) Degree Graduate Degree (N=47) (N=148) (N=86) (N=57) (N=62) 40.4% 32.4% 38.2% 51.2% 49.1% 45.2% 36.2 46.6 39.0 34.9 28.1 27.4 10.6 8.8 9.8 2.3 5.3 8.1 8.5 8.1 8.1 8.1 8.8 9.7 4.3 4.1 4.1 2.3 8.8 9.7 --0.8 1.2 --$.06 $.06 $.06 $.05 $.07 $.07 $.03 $.03 $.02 $.00 $.01 $.01 * When the amount of the difference is a positive value, this indicates that Previous Balance is the greater of the two. ** Omitting three respondents that did not answer the question concerning education. TABLE5-22 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) Share of Total Dollar Difference by Education Level Education N Grade school 24 Some high 47 School High school 148 Graduate Some college 123 Undergraduate 86 College degree Some post57 Graduate Advanced college 62 Degree Total 547* Percent of Total Average Percent of Index Total sample Difference Monthly Total difference B / A (A) By group Difference (B) 4.4 $18.00 $.06 4.4 100.0 8.5 33.96 .06 8.3 97.6 26.9 108.84 .06 26.5 98.5 22.4 15.6 94.56 49.68 .06 .05 23.0 12.1 102.7 77.6 10.4 45.24 .07 11.0 105.8 11.3 55.44 .07 13.5 119.5 99.5* $410.76 $.06 98.8* --- * Omitting three respondents who did not answer the question regarding education. 81 Differences in Cost as Related to Income Distribution of the differences between ADBW and ADBX by household income group is shown in Table 5-29. The mean differences shown in this table indicate that there is some variation in the impact of the cost differences according to income. While the average difference per month for all accounts amounted to $.07, the figures range from $.03 to $.08 according to level of income. Median figures also indicate some variation by income but to a lesser degree—$.00 to $.03 a month. According to the mean differences in Table 5-29, the dollar impact of the cost differences between these two methods falls most heavily on families with incomes over $10,000. Least affected are families with incomes between $7,501 and $10,000. In comparing Previous Balance to TADB, a situation exists similar to that mentioned earlier in the discussion regarding Previous Balance and ADBW. That is, in any given instance either of the two billing methods can be the more expensive, depending upon the customer's payment and purchase patterns. When Previous Balance was less expensive than TADB, the monthly difference ranged from $.01 to $3.27, with an average monthly difference of $.26. Previous Balance was more expensive for only 93 accounts (10.75% of the sample) with monthly cost differences ranging from $.01 to $.36, and averaging $.07 monthly. Zero differences between these two billing methods occurred in only 11 accounts. When the Previous Balance System results in greater finance charges than TADB, it is usually a result of the customer having made an initial purchase on his account and then paying his required monthly installments without making any additional purchases during the payback period. Even this situation would not result in higher finance charges under a Previous Balance system if the customer always took the full amount of time allotted to him for making his payments. But as mentioned earlier, customers, on the average, make their payments approximately 15 days after the billing date rather than taking the full 30 days available to them. Differences in Cost as Related to Income To determine the impact of the cost differences between Previous Balance and TADB in relation to household income, the monthly differences were distributed according to income group as shown in Table 5-24. From these data it is evident that the impact of the cost differences between these two methods varies among income groups, with the average monthly differences increasing in amount as the level of income rises. For example, for families with incomes of $7,500 or less, the average monthly cost difference amounted to $.15 (median difference was $14), whereas for higher income groups, the average differences ranged from $.20 to $.37 a month. This indicates that if a change were made from a Previous Balance system to a TADB system, finance charges for most customers would increase, but increases would be relatively larger for families with higher incomes. 82 TABLE 5-23 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO TRUE ACTUARIAL AVERAGE DAILY BALANCE (TADB) (Original Sample as Compared to Demographic Survey) Original sample Demographic survey (865 Accounts) (550 Accounts) Amount of difference* Number Percent Number Percent -$1.01 or less 15 1.734% 12 2.181% -.76 to 1.00 26 3.006 16 2.909 -.51 to .75 56 6.474 38 6.909 -.26 to .50 204 23.584 140 24.455 -.16 to .25 151 17.457 94 17.091 -.11 to .15 83 9.595 52 9.455 -.01 to .10 266 26.127 131 23.818 $.00 11 1.272 8 1.454 +.00 to .10 75 8.671 48 8.727 +.11 to .15 9 1.040 6 1.091 +.16 to .25 6 .694 5 .909 +.26 or more 3 .347 0 .000 Total 865 100.000% 550 100.000% Positive values 93 10.751% 59 10.727% Negative values 761 87.977 483 87.818% Mean difference, -$.23 -$.24 All accounts Median difference, -$.17 -$.17 All accounts Range of differences -$3.27 to +$.36 -$2.26 to +$.20 Mean difference, $.07 $.07 Positive values only Median difference, $.06 $.06 Positive values only Mean difference, -$.26 -$.28 Negative values only Median difference, -$.19 -$.21 Negative values only * Where the amount of the difference is a positive value, Previous Balance is the greater of the two. Source: For the Original Sample, data were taken from a 12-month history of account records. For the Demographic Survey, data were taken from the same source but restricted to account records of those customers responding to the questionnaire. Particular attention is often given to the fact that finance charges under a Previous Balance system can exceed those under TADB. The reason for this concern is that when this occurs, the actuarial rate involved has exceeded whatever "nominal" annual percentage rate was stated on the contract, giving rise to questions concerning its legality. This point was discussed earlier in Chapter 2. As noted above, this did occur for 93 customers, butfor75of these instances, the difference in cost amounted to no more than $.10 a month or $1.20 for the 12-month period. 83 Where TADB exceeds Previous Balance: As mentioned earlier, in given instances it is possible for Previous Balance to be more expensive than TADB. However, as shown by the data in Table 5-25 TADB was the more costly of the two methods of assessment for 483 accounts out of the 550 (88%) returning the demographic questionnaire (also for 761 or 88% of the original sample). The Index values in Table 5-25 show that the dollar impact of the cost differences between Previous Balance and TADB, when the latter is more expensive, consistently rises with the level of household income Thus, if a creditor were to change from TADB to Previous Balance, the higher the income of the family the more it would stand to benefit from the change. These data, in effect, substantiate the findings as discussed earlier from Table 5-24. Where Previous Balance exceeds TADB: As indicated earlier, for approximately 10% of the total sample (59 out of 550), use of the Previous Balance method resulted in greater finance charges than would have a TADB system. No attempt can be made to examine these instances because of the small number of observations involved. The total number of instances in which Previous Balance exceeds TADB itself is small (59); but when these are further categorized by income and education levels, the individual cell sizes become extremely small (less than ten in most instances). Cost Differences as Related to Education A distribution of the monthly cost differences by education level is shown in Table 5-26. As was true with income, there is a variation in the dollar impact of the cost differences, with the higher educational levels bearing a heavier load. For example, families in the Grade School group experienced an average monthly difference of $15, whereas families with more education had cost differences ranging from $.17 to $.31 monthly. Therefore, it is families with higher educational attainment that would be most affected by a change in billing method from Previous Balance to TADB. TABLE 5-24 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO TRUE ACTUARIAL AVERAGE DAILY BALANCE (TADB) BY HOUSEHOLD INCOME GROUP Amount of Difference* Total Sample (N = 550) -$1.01 or less -.76 to 1.00 -.51 to .75 -.26 to .50 -.16 to .25 -.11 to .15 -.01 to .10 $.00 +.01 to .10 +.11 to .15 +.16 to .25 Mean difference Median difference 2.2% 2.9 6.9 25.5 17.1 9.5 23.8 1.5 8.7 1.1 0.9 -$.24 -$.17 Household Income** $7,500 or $7,501- $10,001- $15,001- $20,001- $25,000less ($10,000 15,000 20,000 25,000 or more (N=52) (N=54) (N=146) (N=129) (N=69) (N=38) --2.1% 1.6% 1.4% 6.8% -1.9% 1.4 3.1 4.3 6.8 1.9% 9.3 2.7 6.2 11.6 13.6 21.2 22.2 23.3 23.3 33.3 27.3 21.2 22.2 19.2 17.1 14.5 10.2 13.5 9.3 8.2 10.1 7.2 10.2 34.6 24.1 27.4 24.0 14.5 19.3 -3.7 2.1 0.8 1.4 1.1 3.8 7.4 12.3 11.6 8.7 2.3 1.9 -0.7 0.8 1.4 1.1 1.9 -0.7 0.8 1.4 1.1 -$.15 -$.22 -$.20 -$.22 -$.28 -$.37 -$.14 -$.17 -$.13 -$.17 -$.27 -$.31 *Where the amount of the difference is a positive value, Previous Balance is the greater of the two. ** Omitting 12 respondents that did not answer the question concerning income. 84 TABLE 5-25 AVERAGE MONTHLY DIFFERENCES IN DOLLAR FINANCE CHARGES, WHERE TRUE ACTUARIAL AVERAGE DAILY BALANCE (TADB) EXCEEDS PREVIOUS BALANCE (483 Accounts) Share of Total Dollar Difference by Income Group Household Income N Percent of Total Average Percent of Index Total sample Difference Monthly Total difference B / A (A) By group Difference (B) $7,500 or less 48 9.9% $98.16 $.170 6.0% 60.6 $7,501-10,000 48 9.9 142.20 .247 8.7 87.9 10,001-15,000 123 25.5 369.48 .250 22.6 88.6 15,001-20,000 110 22.8 361.44 .274 22.1 96.9 20,001-25,000 60 12.4 241.32 .335 14.7 118.5 25,001 or more 83 17.2 390.24 .392 23.8 138.4 Total 472* 97.7%* $1,638.36 -$.26 97.9%* --* Omitting 11 respondents that did not answer the question concerning income. Where TADB exceeds Previous Balance: For the 483 accounts (approximately 90% of total sample) where TADB would have resulted in greater finance charges than Previous Balance, the total dollar impact of the cost differences are shown by the data in Table 5-27. Again, with allowances for the small number of observations in certain groups (i.e., Grade School, Some High School), the Index values indicate that the dollar impact of the cost differences increases with the level of educational attainment. Thus, a change from TADB to Previous Balance would produce greater relative gains to those families with higher levels of education Where Previous Balance exceeds 7ADB- As stated in the discussion concerning relation of these instances to income level the number of observations makes any discussion of no value. Average Daily Balance Including Debits as Compared to Average Daily Balance Excluding Debits All of the comparisons treated up to now have included the Previous Balance method, which was the method actually used on accounts included in this study. Using simulations of other methods of assessing finance charges, other possible combinations of billing methods may be examined. Among the average daily balance systems in use today, the most common are those that either include current month's purchases (ADBW) or that exclude them (ADBX). Less common is the TADB system which includes current's month's purchases and excludes all “free time.” Data in Table 5-28 illustrate the monthly cost differences that would have resulted between an ADBW system and ADBX. For over half of the customers, there would have been no difference at all over the year. Zero differences would result from instances where the customer paid his account in full and avoided finance charges entirely (26% of all accounts) or when no new purchases were made on an account during a billing period. For example, if a customer owes a balance of $100 on August 1, makes a single payment of $10 on August 16, and makes no new purchases during August, then the ADBW and ADBX result in the same finance charge for the billing period ending on August 31. Likewise, if the $ 100 balance were paid in full during the month of August there would be no finance charge at all under either ADB system. 85 TABLE 5-26 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, PREVIOUS BALANCE AS COMPARED TO TRUE ACTUARIAL AVERAGE DAILY BALANCE (TADB) BY EDUCATION LEVEL Amount of Difference* Total Sample (N = 550) -$1.01 or less -.76 to 1.00 -.51 to .75 -.26 to .50 -.16 to .25 -.11 to .15 -.01 to .10 $.00 +.01 to .10 +.11 to .15 +.16 to .25 Mean difference Median difference 2.2% 2.9 6.9 25.5 17.1 9.5 23.8 1.5 8.7 1.1 0.9 -$.24 -$.17 Level of Education** Grade Some High Some Undergraduate Some Advanced School High School College College PostCollege (N=24) School Graduate (N=123) Degree Graduate Degree (N=47) (N=148) (N=86) (N=57) (N=62) --2.7% 0.8% 1.2% 5.3% 4.8% --2.0 2.4 4.7 5.3 4.8 4.2% 8.5% 3.4 4.1 18.6 5.3 4.8 16.7 17.0 27.7 25.2 26.7 19.3 35.5 16.7 19.1 16.9 18.7 12.8 15.8 21.0 8.3 4.3 8.8 13.0 14.0 7.0 4.8 45.8 40.4 5.7 17.1 12.8 31.6 17.7 4.2 -1.4 1.6 1.2 3.5 --10.6 9.5 16.3 7.0 3.5 1.6 --1.4 0.8 1.2 1.8 1.6 4.2 -0.7 --1.8 3.2 -$.15 -$.17 -$.22 -$.21 -$.31 -$.27 -$.31 -$.09 -$.10 -$.17 -$.17 -$.27 -$.17 -$.27 * When the amount of the difference is a positive value, this indicates that Previous Balance is the greater of the two. ** Omitting three respondents that did not answer question concerning education. TABLE 5-27 AVERAGE MONTHLY DIFFERENCES IN DOLLAR FINANCE CHARGES, WHERE TRUE ACTUARIAL AVERAGE DAILY BALANCE (TADB) EXCEEDS PREVIOUS BALANCE (483 Accounts) Share of Total Dollar Difference by Education Level Education N Percent of Total Average Percent of Index Total sample Difference Monthly Total difference B / A (A) By group Difference (B) 4.6% $45.00 $.170 2.7% 58.7 8.7 98.04 .195 6.0 69.0 Grade school 22 Some high 42 School High school 129 26.7 402.84 .260 24.6 92.1 Graduate Some college 100 20.7 326.76 .272 19.9 96.1 Undergraduate 78 16.1 328.80 .351 20.1 124.8 College degree Some post51 10.6 189.48 .310 11.6 109.4 Graduate Advanced college 58 12.0 240.24 .345 14.7 122.5 Degree Total 480* 99.4%* $1,638.36 $.28 99.6%* --* Omitting three respondents that did not answer the question concerning education. 86 The relative dollar impact is also indicated clearly by the Index values shown in Table 5-30. These indices point to the same income groups bearing the heaviest impact as mentioned above. Thus a change from ADBW to ADBX would have the most benefit for middle- and upper-income families, while lower income groups experience a smaller difference in cost. Conversely, a switch from ADBX to ADBW results in a greater burden on middle- and upper-income families. TABLE 5-28 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) (Original Sample as Compared to Demographic Survey) Original sample Demographic survey (865 Accounts) (550 Accounts) Amount of difference* Number Percent Number Percent $.00 443 51.214% 274 49.818% +.01 to .10 228 26.358 150 27.273 +.11 to .15 61 7.052 46 8.364 +.16 to .25 70 8.092 46 8.364 +.26 .50 49 5.665 25 4.545 +.51 to .75 11 1.272 7 1.273 +.76 to .89 3 .347 2 .364 Total 865 100.000% 550 100.001% Mean (Average) $.07 $.07 Difference Median difference $.00 $.01 Range of differences $.00 to $.89 $.00 to $.88 * Where the amount of the difference is a positive value, Average Daily Balance Including Debits is larger than Average Daily Balance Excluding Debits. Source: For the Original Sample, data were taken from a 12-month history of account records. For the Demographic Survey, data were taken from the same source but restricted to account records of those customers responding to the questionnaire. Differences in Cost as Related to Education A distribution of the monthly cost differences between ADBW and ADBX by educational level is shown in Table 5-31. From these data, particularly the mean and median differences, little variation in the cost differences for one education level as compared to another is in evidence. For the total sample, the average monthly cost difference was $.07. Among levels of education, the figures range from $.06 to $.08 a month, a cost difference of only $.02 a month. The median figures indicate even less variati6n, ranging from $.00 to $.01. Index values measuring the proportionate share of the total dollar differences by educational level are shown in Table 5-32. As indicated there is no consistent pattern displayed, probably because of the minimal nature of the cost differences. 87 TABLE 5-29 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) BY HOUSEHOLD INCOME GROUP Household Income** $7,500 or $7,501- $10,001- $15,001- $20,001- $25,000less ($10,000 15,000 20,000 25,000 or more (N=52) (N=54) (N=146) (N=129) (N=69) (N=38) $.00 49.8% 53.8% 61.1% 37.7% 45.0% 58.0% 56.8% +.01 to .10 27.3 28.8 27.8 33.6 27.9 20.3 22.7 +.11 to .15 8.4 9.6 1.9 12.3 10.1 5.8 5.7 +.16 to .25 8.4 1.9 9.3 11.0 10.9 8.7 4.5 +.26 to .50 4.5 3.8 -4.1 4.7 7.2 6.8 +.51 to .75 1.3 1.9 -0.7 1.6 -2.3 +.76 to .89 0.4 --0.7 --1.1 Mean difference $.07 $.05 $.03 $.08 $.07 $.06 $.07 Median difference $.01 $.00 $.00 $.03 $.01 $.00 $.00 * Where the amount of the difference is a positive value, this indicates that Average Daily Balance Including Debits is the larger of the two. ** Omitting 12 respondents that did not answer the question concerning income. Amount of Difference* Total Sample (N = 550) TABLE 5-30 AVERAGE MONTHLY DIFFERENCE IN DOLLAR FINANCE CHARGES, AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) Share of Total Dollar Difference by Income Group Household Income N Percent of Total Average Percent of Total sample Difference Monthly Total difference (A) By group Difference (B) $7,500 or less 52 9.5 $33.36 $.05 7.6 $7,501-10,000 54 9.8 21.48 .03 4.9 10,001-15,000 146 26.5 134.04 .08 30.7 15,001-20,000 129 23.5 110.88 .07 25.4 20,001-25,000 69 12.5 50.40 .06 11.6 25,001 or more 88 16.0 77.88 .07 17.9 Total 538* 97.8* $436.08 $.07 98.1%* * Omitting 12 respondents that did not answer the income question. 88 Index B/A 80.0 50.0 115.8 108.1 92.8 111.9 --- TABLE 5-31 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING (ADBX) BY EDUCATION LEVEL Amount of Difference* Total Sample (N = 550) $.00 +.01 to .10 +.11 to .15 +.16 to .25 +.26 to .50 +.51 to .75 +.76 to .89 Mean difference Median difference 49.8% 27.3 8.4 8.4 4.5 1.3 0.4 $.07 $.01 Level of Education** Grade Some High Some Undergraduate Some Advanced School High School College College PostCollege (N=24) School Graduate (N=123) Degree Graduate Degree (N=47) (N=148) (N=86) (N=57) (N=62) 45.8% 48.9% 44.6% 46.3% 64.0% 52.6% 51.6% 29.2 29.8 31.1 31.7 15.1 17.5 32.3 8.3 8.5 10.1 7.3 8.1 10.5 3.2 8.3 8.5 10.1 7.3 8.1 10.5 3.2 4.2 4.3 6.1 3.3 4.7 5.3 3.2 4.2 -0.7 2.4 -1.8 1.6 ---0.8 1.2 --$.08 $.06 $.06 $.07 $.06 $.08 $.06 $.01 $.01 $.01 $.01 $.00 $.00 $.00 *Where the amount of the difference is a positive value, this indicates that Average Daily Balance Including Debits is the larger of the two. ** Omitting three respondents that did not answer the question concerning education. Adjusted Balance as Compared to Average Daily Balance Including Debits Since current monthly payments and credits are deducted from the beginning balance and current month's purchases are not included in the balance, the Adjusted Balance method generally results in smaller finance charges than all other methods. In an earlier section, a comparison was made between the results of Adjusted Balance as opposed to Previous Balance. In this instance, the monthly cost differences amounted to $.15 on the average. In the two following sections, the Adjusted Balance will be contrasted first with the ADBW system and then with ADBX. A distribution of the cost differences between Adjusted Balance and ADBW is shown in Table 5-33. As indicated, the average monthly difference amounted to $.15 (same as between Adjusted and Previous Balance). Cost differences ranged from $.00 to $2.16 a month. As has been true in each comparison made to this point, there were a large number of accounts for which there was zero cost difference-40% in this instance. Zero differences occur primarily because customers often pay their account balances in full upon receipt of statement, thereby avoiding finance charges entirely. Zero differences can also result between Adjusted Balance and ADBW either when no payment is made on account during the month or when there are no purchases on an account during the current month and the payment is made very early in the billing period. Cost differences amounted to between $.01 and $. 10 a month for 22% of the accounts. Thus, for approximately 62% of the customers, there was either no difference or a difference of no more than $1.20 yearly. Although cost differences were generally minimal, for a few customers there was a substantial variation. For example, the monthly difference would have exceeded $1 a month on eight accounts (see Table 5-33). Cost differences ranged from $.26 to $1 a month for approximately 20% of the customers. 89 TABLE 5-32 AVERAGE MONTHLY DIFFERENCE IN DOLLAR FINANCE CHARGES, AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) Share of Total Dollar Difference by Education Education N Percent of Total Average Percent of Index Total sample Difference Monthly Total difference B / A (A) By group Difference (B) 4.4 $22.68 $.08 5.2 118.2 8.5 31.08 .06 7.1 83.5 Grade school 24 Some high 47 School High school 148 26.9 113.88 .06 26.1 97.0 Graduate Some college 123 22.4 106.32 .07 24.4 108.9 Undergraduate 86 15.6 60.72 .06 13.9 89.1 College degree Some post57 10.4 53.28 .08 12.2 117.3 Graduate Advanced college 62 11.3 43.92 .06 10.1 89.4 Degree Total 547* 99.5* $436.08 $.07 99.0%* --* Omitting three respondents who did not answer the question regarding education. TABLE 5-33 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, ADJUSTED BALANCE AS COMPARED TO AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) (Original Sample as Compared to Demographic Survey) Original sample Demographic survey (865 Accounts) (550 Accounts) Amount of difference* Number Percent Number Percent $.00 346 40.000% 213 38.727% - .01 to .10 192 22.197 123 22.364 - .11 to .15 50 5.780 34 6.182 - .16 to .25 84 9.711 56 10.182 - .26 .50 120 13.873 81 14.727 - .51 to .75 46 5.318 25 4.545 - .76 to .89 19 2.197 13 2.364 - 1.01 to 1.25 3 3.47 2 .364 - 1.26 to 1.50 4 .462 2 .364 - 1.51 to 2.16 1 .116 1 .182 Total 865 100.001% 550 100.001% Mean (Average) -$.15 -$.15 Difference Median difference -$.03 -$.04 Range of differences $.00 to -$2.16 $.00 to -$2.16 * Where the differences are negative values, Adjusted Balance is the smaller of the two. Source: For the Original Sample, data were taken from a 12-month history of account records. For the Demographic Survey, data were taken from the same source but restricted to account records of those customers responding to the questionnaire. 90 Differences in Cost as Related to Income For different income groups, a distribution of cost differences between Adjusted Balance and ADBW is shown in Table 5-34. The mean differences indicate that there are, in some cases, substantial variations among income groups. For example, while the average monthly difference for the total sample was $15, by income group the averages ranged from $.09 to $18. These data indicate that differences were greatest for middle- and upper-income families. For example, in the $7,500 or less group, average monthly differences amounted to $.13 (next to the lowest of all groups); for families with incomes between $7,501 and $10,000, average monthly difference was $.09 (lowest of all groups). On the other hand, average monthly differences amounted to $.16 or more for all but one income group above $10,000. TABLE 5-34 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, ADJUSTED BALANCE AS COMPARED TO AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) BY HOUSEHOLD INCOME GROUP Amount of Difference* Total Sample (N = 550) $.00 - .01 to .10 - .11 to .15 - .16 to .25 - .26 to .50 - .51 to .75 - .76 to 1.00 -1.01 to 1.25 -1.26 to 1.50 -1.51 to 2.16 Mean difference Median difference 38.7% 22.4 6.2 10.2 14.7 4.5 2.4 0.4 0.4 0.2 -$.15 -$.03 Household Income** $7,500 or $7,501- $10,001- $15,001- $20,001- $25,000less ($10,000 15,000 20,000 25,000 or more (N=52) (N=54) (N=146) (N=129) (N=69) (N=38) 44.2% 44.4% 24.0% 34.1% 47.8% 51.1% 23.1 22.2 28.1 22.5 18.8 17.0 3.8 13.0 5.5 7.0 4.3 4.5 11.5 5.6 13.7 12.4 8.7 5.7 9.6 14.8 21.2 15.5 10.1 11.4 5.8 -4.1 6.2 5.8 4.5 1.9 -2.7 1.6 4.3 3.4 ---0.8 ----0.7 --1.1 -----1.1 -$.13 -$.09 -$.18 -$.16 -$314 -$.16 -$.025 -$.015 -$.095 -$.05 -$.01 $.00 * When the amount of the difference is a negative value, this indicates that Adjusted Balance is the smaller of the two. ** Omitting 12 respondents that did not answer the question concerning income. The Index values in Table 5-35 also show clearly that the impact of the cost differences between Adjusted Balance and ADBW falls most heavily on middle- and upper-income families. Families with incomes between $10,001 and $15,000 with an Index value of 117.7 receive the heaviest weight of the cost differences. Except for the $20,001 to $25,000 bracket, all families with incomes over $10,000 had Index values greater than 100, indicating a larger than relative share of the total dollar cost difference. It is evident that if a creditor were to change from Adjusted Balance to ADBW, the burden of the additional finance charges imposed would fall most heavily on middle- and upper-income families, not on lower-income customers. Conversely, if a creditor were to change from ADBW to Adjusted Balance, middle and upper income groups would benefit most. 91 Differences in Cost as Related to Education A distribution of the cost differences between Adjusted Balance and ADBW by educational level is shown in Table 5-36. Mean and median differences display some (although small) variation by level of education. Mean difference for the total sample was $.15 a month; by education level, differences ranged from $.13 to $.16 a month. Median differences show a somewhat wider variation with cost differences ranging from $.00 to $.08 a month. TABLE 5-35 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, ADJUSTED BALANCE AS COMPARED TO AVERAGE DAILY BALANCE INCLUDING DEBITS (ADB\N) Share of Total Dollar Difference by Income Groups Household Income N Percent of Total Average Percent of Total sample Difference Monthly Total difference (A) By group Difference (B) $7,500 or less 52 9.5 $33.36 $.05 7.6 $7,501-10,000 54 9.8 21.48 .03 4.9 10,001-15,000 146 26.5 134.04 .08 30.7 15,001-20,000 129 23.5 110.88 .07 25.4 20,001-25,000 69 12.5 50.40 .06 11.6 25,001 or more 88 16.0 77.88 .07 17.9 Total 538* 97.8* $436.08 $.07 98.1%* * Omitting 12 respondents that did not answer the income question. Index B/A 80.0 50.0 115.8 108.1 92.8 111.9 --- Although, as indicated above, there are variations among education groups, there is no consistent pattern. Three of the groups with the largest difference ($.16) cover the entire range of education levels-Grade School, Some College, and Advanced College Degree. Additional data concerning the impact of the cost differences by education are shown in Table 5-37. The Index values indicate that the greatest impact falls on three widely divergent groups-Grade School, Some College, and Advanced College Degree. It is these three groups that would stand to benefit most from a change from ADBW to Adjusted Balance. Likewise, the same groups would stand to bear most of the additional finance charges if a change were made from Adjusted to ADBW. It is noteworthy, however, that since the Index values for the three groups are not much over 100, the overall impact of cost differences is not substantially different from that experienced by other education levels. In fact, no education group had an Index value of less than 88.2 or more than 107.6, indicating the relatively small amount of variation in impact. Adjusted Balance as Compared to Average Daily Balance Excluding Debits One final comparison of cost differences to be made concerns Adjusted Balance as related to that type of average daily balance system that excludes current month's purchases in calculation of finance charges. The major difference between these two methods is that under Adjusted Balance a customer is given credit for his payment as if it had been made on the first day of the billing period. That is, it is deducted from his beginning balance regardless of the day on which payment is actually made. The finance charge is then determined on the basis of this "adjusted" balance. Under an ADBX system, a customer is given credit for his payments only from the day that payment is received by the creditor. That is, his daily balance is reduced effective from the day payment is received. (See Chapter 3 for a complete description.) 92 TABLE 5-36 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, ADJUSTED BALANCE AS COMPARED TO AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) BY EDUCATION LEVEL Amount of Difference* Total Sample (N = 550) $.00 - .01 to .10 - .11 to .15 - .16 to .25 - .26 to .50 - .51 to .75 -.76 to 1.00 -1.01 to 1.25 -1.26 to 1.50 -1.51 to 2.16 Mean difference Median difference 38.7% 22.4 6.2 10.2 14.7 4.5 2.4 0.4 0.4 0.2 -$.15 -$.03 Level of Education** Grade Some High Some Undergraduate Some Advanced School High School College College PostCollege (N=24) School Graduate (N=123) Degree Graduate Degree (N=47) (N=148) (N=86) (N=57) (N=62) 37.5% 36.2% 31.1% 36.6% 51.2% 45.6% 41.9% 20.8 25.5 25.7 22.8 19.8 15.8 21.0 8.3 8.5 7.4 8.1 1.2 1.8 8.1 12.5 10.6 14.2 8.1 10.5 8.8 4.8 12.5 14.9 15.5 15.4 5.8 21.1 16.1 4.2 4.3 4.7 4.9 5.8 3.5 3.2 4.2 -0.7 2.4 4.7 3.5 3.2 --0.7 0.8 ------0.8 --1.6 ----1.2 ---$.16 -$.13 -$.14 -$.16 -$.15 -$.15 -$.16 -$.06 -$.08 -$.06 -$.07 -$.00 -$.01 -$.04 * When the amount of the difference is a negative value, this indicates that Adjusted Balance is the smaller of the two. ** Omitting three respondents that did not answer the question concerning education. TABLE 5-37 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, ADJUSTED BALANCE AS COMPARED TO AVERAGE DAILY BALANCE INCLUDING DEBITS (ADBW) Share of Total Dollar Difference by Education Level Education N Grade school 24 Some high 47 School High school 148 Graduate Some college 123 Undergraduate 86 College degree Some post57 Graduate Advanced college 62 Degree Total 547* Percent of Total Average Percent of Index Total sample Difference Monthly Total difference B / A (A) By group Difference (B) 4.4 $46.08 -$.16 4.6 104.5 8.5 74.88 -.13 7.5 88.2 25.9 253.08 -.14 25.3 94.1 22.4 15.6 240.60 150.24 -.16 -.15 24.1 15.0 107.6 96.2 10.4 103.80 -.15 10.4 100.0 11.3 119.64 -.16 12.0 106.2 99.5* $999.60 -$.15 98.9%* --- * Omitting three respondents who did not answer the question regarding education 93 A distribution of the cost differences between Adjusted Balance and ADBX is shown in Table 5-38. Actual differences ranged from $.00 to $1.32 a month and averaged $.08 monthly. For over 40% of the accounts, the differences in finance charges were zero. For an additional 28% of the customers, cost differences amounted to no more than $.10 a month. Fewer than 30% of the accounts experienced cost differences of more than $.10 a month. Thus the minimal cost differences between Adjusted Balance and ADBX are clearly demonstrated by these data. Instances in which the cost differences were significant were quite infrequent. Only two accounts had differences amounting to more than $35 a month, or $9 a year. A total of 15 customers experienced differences of more than $6 a year. Differences in Cost as Related to Income Although the cost differences between Adjusted Balance and ADBX are usually small, there are variations in the impact of such differences by income level. For example, as shown by the distribution of cost differences by income group in Table 5-39, mean differences by income group ranged from $.05 to $.10 a month, compared to an average monthly difference of $.08for the entire sample. Median differences also indicate a variation in the impact by income with values ranging from $.00 to $.05 a month. The impact of the cost differences is greatest on middle and upper income groups (except for the $20,001 to $25,000 bracket). This is indicated by the fact that families with incomes of between $10,001 and $15,000 experienced monthly differences averaging $10. Customers in the $15,001 to $20,000 and $25,001 and over brackets had monthly differences averaging $.09. Conversely, families with incomes of $7,501 to$10,000and $7,500 or less had monthly differences averaging $.05 and $.07, respectively. TABLE 5-38 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, ADJUSTED BALANCE AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) (Original Sample as Compared to Demographic Survey) Original sample Demographic survey (865 Accounts) (550 Accounts) Amount of difference* Number Percent Number Percent $.00 375 43.353% 232 42.182% - .01 to .10 241 27.861 158 28.727 - .11 to .15 77 8.902 53 9.636 - .16 to .25 89 10.289 54 9.818 - .26 .50 68 7.861 44 8.000 - .51 to .75 13 1.503 7 1.273 - .76 to 1.00 1 .116 1 .182 - 1.01 to 1.32 1 .116 1 .182 Total 865 100.001% 550 100.000% Mean (Average) -$.08 -$.09 Difference Median difference -$.02 -$.02 Range of differences $.00 to -$1.32 $.00 to -$1.32 * Where the amount of the difference is a negative value, Adjusted Balance is the smaller of the two. 94 Source: For the Original Sample, data were taken from a I 2-month history of account records. For the Demographic Survey, data were taken from source but restricted to account records of those customers responding to the questionnaire. The above description further is evidenced by data in Table 5-40 showing the relative share of total dollar difference by income group. Those incomes with Index values of more than 100 (indicating a larger than proportionate share of the total dollar difference) are the same groups referred to above as bearing the greatest impact. Thus if a creditor were to change from Adjusted Balance to ADBX, the additional finance charges imposed would fall more heavily on middle- and upper-income families than on customers with less income. Conversely, if a creditor were to switch from ADBX to Adjusted Balance, it would be families with middle and upper incomes that would gain to the greatest extent. TABLE 5-39 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, ADJUSTED BALANCE AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) BY HOUSEHOLD INCOME GROUP Household Income** Amount of Total Sample $7,500 or $7,501- $10,001- $15,001- $20,001- $25,000Difference* (N = 550) less ($10,000 15,000 20,000 25,000 or more (N=52) (N=54) (N=146) (N=129) (N=69) (N=38) $.00 42.2% 44.2% 44.4% 28.1% 36.4% 50.7% 60.2% - .01 to .10 28.7 28.8 35.2 34.2 32.6 23.2 15.9 - .11 to .15 9.6 11.5 9.3 15.1 8.5 4.3 6.8 - .16 to .25 9.8 5.8 11.1 12.3 10.9 11.6 5.7 - .26 to .50 8.0 9.6 -8.2 10.9 8.7 6.8 - .51 to .75 1.3 --21.0 0.8 1.4 2.3 - .76 to 1.00 0.2 -----1.1 -1.01 to 1.32 0.2 -----1.1 Mean difference -$.08 -$.07 -$.05 -$.10 -$.09 -$.08 -$.09 Median difference -$.02 -$.02 -$.01 -$.05 -$.03 $.00 $.00 * When the amount of the difference is a negative value, Adjusted Balance is the smaller of the two. ** Omitting 12 respondents that did not answer the question concerning income. TABLE 5-40 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, ADJUSTED BALANCE AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) Share of Total Dollar Difference by Income Group Household Income N Percent of Total Average Percent of Total sample Difference Monthly Total difference (A) By group Difference (B) $7,500 or less 52 9.5 $46.20 -$.07 8.2 $7,501-10,000 54 9.8 34.20 -.05 6.1 10,001-15,000 146 26.5 177.84 -.10 31.6 15,001-20,000 129 23.5 136.44 -.09 24.3 20,001-25,000 69 12.5 66.12 -.08 11.8 25,001 or more 88 16.0 95.16 -.09 16.9 Total 538* 97.8* $562.20 -$.09 98.9%* * Omitting 12 respondents that did not answer the income question. 95 Index B/A 86.3 62.2 119.2 103.4 94.4 105.6 --- Differences in Cost as Related to Education A distribution of the cost differences between Adjusted Balance and ADBX by educational level is shown in Table 5-41. These data indicate generally that there is less variation in impact according to education than was true according to income. For example, average monthly differences ranged from $.07 to $10, a difference of only $.03 a month. What variation in impact does exist, however, indicates that families with higher levels of education (except for the Some Post-Graduate group) tend to bear a greater degree of the impact than do those with less education. This is further evidenced by data in Table 5-42 showing the relative share of the total difference accounted for by each education group. Except for families in the Some Post-Graduate group, all customers with more than a high school education had Index values exceeding 100, indicating a larger than proportionate share of the total dollar difference that occurred. Thus any change in billing method from Adjusted Balance to ADBX or the reverse would have more impact (gain or loss) on families with higher levels of education, but this impact is small in any event. IMPACT OF METHOD OF ASSESSING FINANCE CHARGES ON YIELD TO THE CREDITOR To this point, seven possible combinations of methods of assessing finance charges on revolving charge accounts have been considered. In each instance, consideration has been given to the general magnitude of the cost differences to consumers that result. The possibility that certain income and education groups may be affected more than others has also been examined in detail. It has been observed that for a great majority of customers, differences in finance charges resulting from usage of various assessment methods are minimal. For a few customers it may be said that such differences are significant. That cost differences to the average customer may be insignificant, however, does not mean that the impact on a creditor's total finance charge revenue is equally minimal since a large number of "small" differences can rapidly add to a significant sum. Table 5-43 provides data relative to the total revenue from finance charges and the annual yield achieved by the creditor under each of the six assessment methods that were considered. The Index values facilitating comparison of one method with another were calculated relative to the Previous Balance method since it was the method actually in use by the creditor on whose accounts this study is based. Total finance charge revenues under any of the other billing methods could have been used to compute similar indices. The largest yield to creditors results from use of the True Actuarial Average Daily Balance—approximately 21% greater than that obtained from the Previous Balance system. One method, Ending Balance, also produces substantially more revenue than does Previous Balance. Conversely, the Adjusted Balance system results in 12% less revenue than Previous Balance. Further insight into the degree of impact on a creditor from use of Adjusted Balance is gained by comparing total revenue at 11/2% per month under Adjusted Balance with a 1% per month rate of charge under the TADB system. As shown in Table 5-43, total revenue produced by Adjusted Balance at 1 ½% per month amounted to $11,325.17. This figure is only5% more than what would have been obtained had a TADB system been used with a monthly charge of 1%! 96 TABLE 5-41 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, ADJUSTED BALANCE AS COMPARED TO AVFRAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) BY EDUCATION LEVEL Amount of Difference* Total Sample (N = 550) $.00 - .01 to .10 - .11 to .15 - .16 to .25 - .26 to .50 - .51 to .75 -.76 to 1.00 -1.01 to 1.32 Mean difference Median difference 42.2% 28.7 9.6 9.8 8.0 1.3 0.2 0.2 -$.08 -$.02 Level of Education** Grade Some High Some Undergraduate Some Advanced School High School College College PostCollege (N=24) School Graduate (N=123) Degree Graduate Degree (N=47) (N=148) (N=86) (N=57) (N=62) 37.5% 36.2% 36.5% 39.0% 53.5% 50.9% 46.8% 33.3 36.2 31.8 30.9 22.1 21.1 25.8 8.3 6.4 13.5 8.9 10.5 5.3 8.1 12.5 17.0 12.2 9.8 2.3 14.0 4.8 8.3 2.1 6.1 9.8 9.3 8.8 8.1 ---1.6 1.2 -4.8 ------1.6 ----1.2 ---$.08 -$.08 -$.08 -$.09 -$.09 -$.07 -$.10 -$.025 -$.02 -$.06 -$.03 $.00 $.00 -$.02 * When the amount of the difference is a negative value, this indicates that Adjusted Balance is smaller of the two. ** Omitting three respondents that did not answer the question concerning education. TABLE 5-42 DIFFERENCES IN AVERAGE MONTHLY DOLLAR FINANCE CHARGES, ADJUSTED BALANCE AS COMPARED TO AVERAGE DAILY BALANCE EXCLUDING DEBITS (ADBX) Share of Total Dollar Difference by Education Level Education N Grade school 24 Some high 47 School High school 148 Graduate Some college 123 Undergraduate 86 College degree Some post57 Graduate Advanced college 62 Degree Total 547* Percent of Total Average Percent of Index Total sample Difference Monthly Total difference B / A (A) By group Difference (B) 4.4 $23.28 -$.08 4.1 93.2 8.5 43.68 -.08 7.8 91.8 26.9 138.84 -.08 24.7 91.8 22.4 15.6 133.92 89.52 -.09 -.09 23.8 15.9 106.3 101.9 10.4 49.92 -.07 8.9 85.6 11.3 75.84 -.10 13.5 119.5 99.5* $562.20 $.09 98.7%* --- * Omitting three respondents who did not answer the question regarding education. 97 One other billing method, ADBX, produced less revenue than Previous Balance. The difference in yield amounted to approximately 5% for the year. One type of average daily balance system, ADBW, produced only slightly more finance charge revenue than did Previous Balance. Total revenue from finance charges under ADBW amounted to $12,899.16 for the year, a difference for the 12-month period of $56.03. The difference in yield amounted to .44% Significance of Varying Yields Granted that substantial variation can result between yields to a creditor depending upon his choice of method of assessing finance charges, a real issue emerges as to the significance of this fact. If a creditor is forced by legislation or reaction to competitive conditions to change to a billing method which produces a lower gross yield of finance charges, certain compensatory action on his part may be required. If the firm has extended credit initially and has determined its price levels in such a way as to earn a normal return on its capital investment, a change in billing method may produce a loss of revenue which must be subtracted from the "bottom line." With no reduction in costs or increases in sales volume to offset the decline in revenues, the creditor is faced with two choices: (1) lower profits and return on investment or (2) improve his return through a reduction of costs or by raising his cash prices. TABLE 5-43 TOTAL DOLLAR FINANCE CHARGE REVENUE AND ANNUAL YIELD UNDER SIX DIFFERENT BILLING METHODS Billing Method Total Revenue* Revenue Per account Per month Previous balance $12,843.13 $1.24 Adjusted balance 11,325.17 1.09 Ending balance 14,648.77 1.41 Average daily balance, 12,899.16 1.24 Including debits Average daily balance, 12,204.10 1.18 Excluding debits True actuarial average 15,228.06 1.47 Daily balance Annual Yield** Index*** 15.928% 14.045 18.167 15.997 100.00 88.18 114.06 100.44 15.135 95.02 18.886 121.32 *All billing methods were based on a monthly rate of finance charge of 11/2% on balances from $33.33 to $500; 1 % per month on that part of the unpaid balance in excess of $500; on balances below $33.33, a $.50 minimum monthly charge was assessed. **Annual yield determined by dividing the total revenue for each billing method by the sum of the true actuarial daily balances ($967,593) and multiplying by 12. ***Total Revenue for each billing method divided by the total revenue produced by the Previous Balance method. Since losses in finance charge revenues may result in higher cash prices and since empirical data produced by this study indicate that the impact of any one assessment method on the finance charges paid by an individual customer is generally small, it would seem that the consumer's interest is not really forsaken if legislative policy allows creditors to determine whatever method is most appropriate for them, considering their respective costs of operations, computer capabilities, customers needs and desires, and other similar factors. This is, essentially, the position taken by the National Commission on Consumer Finance in its report to Congress. In its report, the Commission recommended that: (1) credits for returns should be deducted before 98 determining the balance upon which a finance charge is to be based, (2) that charges for purchases and credits for payments should be treated symmetrically within a billing cycle, and (3) that it is important within these guidelines to leave open as many choices as possible.4 PROBLEMS RESULTING FROM LEGISLATIVE CONTROL OVER ASSESSMENT METHOD One of the basic objectives of legislation as cited in the report of the National Commission on Consumer Finance should be to promote and assure competition.5 With regard to the issue of billing methods, it would seem that this is an equally valid objective. It can be argued that assurance of competition and adequate disclosure of the type of billing method used by the creditor as is now required by the federal Truth in Lending Act provides adequate protection of the consumer's interests. It has been noted that if all companies were to use the same billing method, comparison of costs between different creditors would be facilitated. This is a commendable objective, but even if the assessment method were the same for all creditors, it would still not be possible to predict in advance what the dollar cost or the actual yield would be on the account over a period of time. This is true for all billing methods except True Actuarial Average Daily Balance. Under this method, assuming no minimum monthly charges, the yield would as a percentage rate could be specified. The dollar cost, however, would still be indeterminable. This is accounted for by the fact that repayment terms differ from one creditor to another and because the actual cost to the customer (both in dollars and in true rate)varies according to individual purchase and payments patterns. Even if the above factors were to be ignored or considered insignificant, certain other problems arise in connection with a decision to determine legislatively a single lawful method of assessing charges. For example, the Adjusted Balance method, which is often suggested as "the" method because of the fact that it results in a lower dollar cost to the customer, results in substantially less revenue to the creditor. In the absence of some type of rate relief, this could produce a deficit of revenue in regard to cost with resulting curtailment of credit availability or an increase in cash prices or both. In other words, a change in billing method is comparable to a change in the rate of charge, with all the same potential consequences. Two methods which are actually quite easy to understand and administer-Previous Balance and Ending Balance-produce greater finance charges and, therefore, are often considered unacceptable. This leaves for consideration some type of average daily balance system. The major drawback to use of an ADB system of any type is that a creditor not using a computer in the preparation of his billing statements would find it next to impossible to use this system. The result could be that smaller creditors would be forced to use bank charge plans rather than continue with their own credit operations or obtain billing assistance from outside firms. If forced to use bank cards, the result would be lessened competition and restricted choice for the consumer. 4 5 Report of the National Commission on Consumer Finance, (December 1972), 108. Id. 99 SIGNIFICANT FEATURES: A SUMMARY It is extremely difficult to summarize all of the intricacies of the many possible methods of assessing finance charges on revolving credit accounts. Nevertheless, certain pertinent attributes are notable to each method. The following is an attempt to summarize these as briefly as possible. Previous Balance 1 . Easiest to understand by the consumer and to administer by the creditor. 2. Use of a computer possible but not essential. 3. Produces more finance charge revenue than several other methods. 4. Treats customer purchases and payments alike-neither are taken into consideration during the current month. 5. Retains the privilege of a 30-day charge account with no finance charge when previous balance is paid in full. 6. Does not give customer credit for partial payments which can, in some instances of very large payments, substantially affect customer's costs. 7. Can, in isolated instances, produce a yield on an account greater than the stated rate. Adjusted Balance 1. 2. 3. 4. Relatively easy to understand by the consumer and to administer by the creditor. Use of computer possible but not essential. Retains the privilege of a 30-day charge account with no finance charge when account is paid in full. Usually produces the lowest finance charge because payments are deducted and current month's purchases are excluded. 5. Produces substantially less revenue for the store leading to possible excess of costs over revenues. 6. No motivation to pay early because finance charges do not lessen with early payment. Ending Balance 1. Very easy to understand and administer. 2. Use of computer possible but not essential. 3. Produces substantial finance charge revenue. 4. Eliminates the privilege of a 30-day charge account. 5. Can produce a yield on the account greater than the stated rate. Average Daily Balance Including Debits 1. 2. 3. 4. Retains the privilege of a 30-day charge account with no finance charge when account is paid in full. Treats customer payments and purchases alike. Provides generally more revenue than Adjusted Balance and ADBX Gives customer credit for his payments, thus eliminating large differences in finance charges when substantial payments are made on the account-eliminates "horror" stories cited in reference to Previous Balance system. 5. Makes the cost of the account more closely related to the activity on the account (that is, more purchases result in greater charges). Results in a yield closer to the stated rate than does Adjusted Balance, for example. 6. Encourages prompt and larger payments since finance charges are reduced thereby. 7. Results in less cost as compared to Previous Balance and Ending Balance for customers making an initial purchase which is repaid over time without additional purchases. 100 8. Difficult to understand and to administer. 9. Almost certainly requires use of computers. 10. Can result in greater costs for customers running continual balances with frequent purchases and increasing account balances. Average Daily Balance Excluding Debits 1. 2. 3. 4. 5. 6. 7. 8. 9. Retains the privilege of a 30-day account with no finance charge when account is paid in full. Provides somewhat more finance charge revenue than Adjusted Balance. Somewhat easier to understand and to administer than other forms of ADB. Encourages larger and prompt payments since finance charges are reduced thereby. Produces less cost to customer than several other methods. There is no finance charge on current month's purchases. Probably still will require use of computer to administer. Harder to understand than non-ADB methods. Produces somewhat less revenue than Previous Balance method. True Actuarial Average Daily Balance 1. Provides the greatest revenue of all methods. 2. Results in a yield equal to the stated rate (assuming no minimum charges imposed). 3. Is absolutely "fair" in the-sense that all balances owed by the customer are paid for by him to the exact extent that he owes them. 4. Very difficult to understand and to administer. 5. Most certainly will require use of the computer. 6. Will result in more finance charges for a vast majority of customers. 7. Completely eliminates use of account as a 30-day charge with no finance charge. 8. Leaves overhangs of small finance charge amounts which could be difficult to collect. 101 CHAPTER 6 CUSTOMER AWARENESS OF RATES OF CHARGE AND OTHER ASPECTS OF ACCOUNT USAGE In the previous chapters, an attempt was made to measure various aspects of typical revolving account usage and to determine the effect of a change in the method of assessing finance charges. Another objective of this study was to determine customer awareness of, and attitude toward, rates of finance charge and other billing practices. Specifically, an attempt was made through the use of a demographic questionnaire to determine the following: (1) awareness of annual percentage rates on revolving credit accounts, (2) customer understanding of the dollar cost of financing purchases on revolving credit, (3) whether or not the dollar cost of revolving credit is considered "fair," (4) what amount of finance charge is considered to be fair, (5) significance of billing mistakes or errors, and (6) changes in billing practices deemed to be desirable by customers. AWARENESS OF RATES OF CHARGE1 In Texas, maximum permissible rates of finance charge are 1 ½% per month on balances up to $500, and 1% per month on that part of the unpaid balance in excess of $500 (nominal annual percentage rates of 18% and 12%, respectively). These were the rates charged on the accounts used in this study. The question used to determine awareness of these rates was as follows: When you decide to pay only part of your balance on your department store credit account, what is the annual percentage rate of finance charge (APR) per year? On Balances up to $500 ____________ % On the portion of the balance above $500 __________ % Don't Know________ (X) A degree of confusion may have resulted from use of the word "when" instead of "if" on the question on rates. Some customers indicated on their questionnaire that they never chose the option of paying part of their balance. In such instances, some entered a percentage rate anyway; others checked "Don't know" and some did not answer the question. Thus, the percentage of customers listed as not being aware of the annual percentage rate may be somewhat overstated. A number of customers chose not to answer the question. This may have been because of the wording of the question. On the other hand, it is possible that a customer may have refused to answer the question rather than indicate "Don't Know." In any event, all customers who did not answer the question, for whatever reason, are included in the "Don't Know" or "Knew Neither" category of answers. Only one-third of the respondents reported both the 18% and 12% rates correctly (Table 6-1 ). However, another 23% reported correctly a rate of 18% on balances up to $500. Thus, some rate awareness existed for 56.7% of the total sample. 1 Another significant study on the subject of consumer awareness of rates of finance charge is as follows: Robert P. Shay and Miltion W. Schober. "Consumer Awareness of Annual Percentage Rates of Charge in Consumer Installment Credit: Before and After Truth in Lending Became Effective," Technical Studies, Vol. 1, The National Commission on Consumer Finance. 102 Effect of Income and Education Knowledge of rates increased with the level of income up to $20,000 (Table 6-1). Families with incomes of $25,001 or more showed less awareness of both rates than any other income group except the $7,501 to $10,000 bracket. This maybe a result of the tendency for such income levels to use credit less often than others and therefore have less exposure to rate information. It may also be that at this level of income, the economic significance of rates is much less since customers use this type of credit less and have a bigger cash flow. With the exception of holders of advanced degrees, awareness of rates generally increased with the level of education attained. Awareness of both rates was highest for High School Graduates, but if partial knowledge (that is, knew only one of the rates) is counted, the level of knowledge increases through those in the Some Post-Graduate group. Awareness as Related to Incurrence of Finance Charges Data shown in Table 6-2 indicate that an awareness of the rate of charge is not strongly related to the tendency to revolve balances on revolving accounts, thereby incurring finance charges. For example, customers who were aware of both the 18% and 12% rates had an average monthly finance charge of $1.42 (compared to $1.24 for all accounts). Likewise, these customers incurred finance charges on an average of 5.8 times during the year (compared to 5.1 for all accounts). Conversely, customers who knew neither rate paid an average finance charge of $1.12 a month and incurred finance charges an average of 5.2 times during the year. There is a possibility that better awareness of the rate of charge is a result of paying charges more frequently and, thus, receiving more disclosure of annual percentage rates. In either event, apparently, knowledge of the rate does not discourage use of the account in such a way as to incur charges. CUSTOMER KNOWLEDGE OF THE DOLLAR COST OF REVOLVING CREDIT AT 18% ANNUAL PERCENTAGE RATE Awareness of a percentage rate of charge does not guarantee that a customer understands what that rate means in dollars and cents.2 Many individuals who may be aware of a given percentage rate on a contract are unable to translate the rate into an accurate dollar cost figure. To ascertain the customer's knowledge as to the dollar cost of revolving credit over a year's time, the following question was asked: In your opinion, what would be the dollar finance charge cost of financing a purchase of $100 for 12 months on a department store revolving charge account? This was an open-ended question with space provided in which the customer could write what he believed to be the correct dollar cost. 2 For additional findings on this subject, see: George S. Day and William K. Brandt. "A Study of Consumer Credit Decisions: Implications for Present and Prospective Legislation," Technical Studies, Vol 1, The National Commission on Consumer Finance, 55 ff. 103 TABLE 6-1 KNOWLEDGE OF ANNUAL PERCENTAGE RATE OF CHARGE AS RELATED TO HOUSEHOLD INCOME AND EDUCATION Category N Household Income** $7,500 or less 7,501 to 10,000 10,001 to 15,000 15,001 to 20,000 20,001 to 25,000 25,001 or more Total Education*** Grade school Some high school High school Graduate Some college Undergraduate College degree Some postGraduate Advanced College degree Total Degree Of rate Knowledge Percent Knew 18% and Knew 18% Knew neither Of Total 12% on balances Only above $500 52 54 146 129 69 88 538 24 24 47 148 9.5% 9.8 26.5 23.5 12.5 16.0 97.8% 4.4% 4.4% 8.5 26.9 30.8% 16.7 38.4 41.1 33.3 30.7 33.8% 12.5% 12.5% 25.5 42.3 9.6% 29.6 26.0 22.5 23.2 21.6 22.9% 20.8% 20.8% 19.2 9.1 59.6% 53.7 35.6 36.4 43.5 47.7 43.3% 66.7% 66.7% 55.3 48.6 123 86 22.4 15.6 34.1 38.4 24.4 30.2 41.5 31.4 57 10.4 38.6 29.8 31.6 62 11.3 33.9 22.6 43.5 547 99.5% 33.8% 22.9% 43.3% * Includes those respondents which checked "Don't know" as well as those not answering the question and those reporting incorrect rates. ** Omitting 12 respondents that did not answer question concerning income. *** Omitting three respondents that did not answer question concerning education. TABLE 6-2 KNOWLEDGE OF ANNUAL PERCENTAGE RATES AS RELATED TO FINANCE CHARGE ASSESSMENT Rate knowledge N Know 18% and 12% on balances above $500 Knew 18% only Knew neither* Total 186 Percent Of Total 33.8% 126 22.9 238 43.3 550 100.0% Share of Average Number of times Total finance Monthly Finance charge Charges Finance charges incurred 39.6% $1.42 5.8 20.4 40.0 100.00% 1.08 1.12 $1.24 5.2 5.2 5.1 * Includes those respondents reporting incorrect rates, those checking "Don't know," and those not answering the question. 104 Since all customers included in this study were users of revolving credit accounts, it was assumed in construction of the above question that respondents would understand that revolving accounts require some payment on a monthly basis. In retrospect, it probably would have been more satisfactory had the regular monthly payments and resulting declining balance situation been identified specifically. On some survey answers, respondents evidently were aware of this possibility because they wrote in along with their dollar figure the phrase, "assuming equal monthly payments" or words to that effect. It is not possible to determine the effect, if any, that the wording had on the response. Knowledge of Dollar Cost as Related to Income and Education Over 90% of the respondents overstated what the dollar finance charge would be on a revolving account purchase of $100 over a 1 2-month period, assuming regular monthly payments on the account and no other purchases (see Table 6-3). Regardless of the method of assessment used, the dollar finance charge would not have exceeded $10. Finance charges would have amounted to $9.32 under a Previous Balance system with $.50 minimum charges; other methods would have produced lower charges (see Tables 6-4, 6-5, and 6-6 for examples). Clearly, the most common answer to the question was $18, reported by 40.5% of the respondents. More than 10% felt that the cost would have exceeded $18. The percentage of correct answers (that is, less than $10) generally was higher among upper levels of income. The pattern was not consistent, however, as the percentage of correct answers among families with incomes of $25,001 or more was less than that of the $20,001 to $25,000gro up and about the same as that of the $10,001 to $15,000group. It is noteworthy that for families with incomes of $10,001 or more, the percentage of respondents reporting that the dollar cost would be $18 is substantially larger than for lower-income families. Awareness of the correct dollar charge was much greater among families with higher educational levels (except for Advanced College Degree). Except for the Grade School and Advanced College Degree groups, the percentage of respondents reporting an $18 cost showed little variation by education level. Only 4.2% of those with grade school education reported the cost to be $18, while 51.6% of those with advanced degrees reported an $18 cost (highest percentage of any level). Awareness of Rate as Related to Knowledge of Dollar Cost As indicated by data in Table 6-7, complete or partial knowledge of annual percentage rates of charge does not automatically produce an accurate knowledge of the dollar cost of revolving credit. For example, regardless of the level of rate awareness, the percentage of correct responses to the question on dollar cost ranged from 7.1% to 8.6%. An awareness of the 18% rate did, however, affect the extent to which the respondents reported an $18 cost. For example, over 50% of the respondents with some rate knowledge reported an $18 cost, while less than 20% of those who "Knew Neither" reported this figure. Obviously, when respondents did not know a rate at all, the tendency was to not answer the question calling for an estimated dollar cost (35.7% of those who did not know the rate did not answer this question). 105 TABLE 6-3 OPINION AS TO DOLLAR FINANCE CHARGE ON REVOLVING ACCOUNT AT 18% AS RELATED TO HOUSEHOLD INCOME AND EDUCATION Category N Estimated Percent Less Of Than Total $10 Dollar $10 to $12.49 Finance Charge For a $12.50 $18 More to Than $17.99 $18 Household Income* $7,500 or less 52 9.5% 5.8% 17.3% 1.9% 26.9% 7,501 to 10,000 54 9.8 5.6 14.8 7.4 27.8 10,001 to 15,000 146 26.5 8.9 14.4 6.2 44.5 15,001 to 20,000 129 23.5 6.2 10.1 12.4 43.4 20,001 to 25,000 69 12.5 14.4 11.6 2.9 46.4 25,001 or more 88 16.0 9.1 15.9 2.3 44.3 Total 538 98.7% 8.2% 13.6% 6.2% 40.5% Education** Grade school 24 4.4% 4.2% 16.7% 4.2% 4.2% Some high school 47 8.5 4.3 14.9 6.4 42.6 High school 148 26.9 4.1 14.2 4.8 39.9 Graduate Some college 123 22.4 12.2 11.4 8.1 44.7 Undergraduate 86 15.6 12.8 16.3 7.0 38.4 College degree Some post57 10.4 10.5 12.3 7.0 40.4 Graduate Advanced 62 11.3 4.8 12.9 3.2 51.6 College degree Total 547 99.5% 8.2% 13.6% 6.2% 40.5% *Omitting 12 respondents that did not answer the question concerning income. ** Omitting three respondents that did not answer the question concerning education. Year No Answer -9.4% 13.0 15.7 10.0 9.1 11.3% 48.1% 35.2 13.0 12.4 14.5 18.2 20.2% 4.2% 6.4 11.6 66.7% 25.5 25.7 12.3 9.3 11.4 16.3 17.7 12.3 12.9 14.5 11.3% 20.2% Knowledge of Dollar Cost as Related to Incurrence of Finance Charges It was indicated earlier that the practice of revolving an account with the resulting imposition of finance charges was not significantly related to the likelihood of awareness of annual percentage rate. Data in Table 6-8 indicate that knowledge of the dollar cost is also unaffected by incurrence of finance charges. 106 TABLE 6-4 AN ILLUSTRATION OF THE TOTAL FINANCE CHARGE REVENUE AND ANNUAL PERCENTAGE RATE ON A REVOLVING ACCOUNT AT A MONTHLY CHARGE OF 11/2%, PREVIOUS BALANCE METHOD Month January February March April May June July August September October November December Total Average monthly Balanceg Annual percentage Rateh Unpaid Balancea $100.00 100.00 91.50 82.87 74.11 65.22 56.20 47.04 37.75 28.32 18.74 (18.82) 9.02 $710.77 (711.15)e $59.23 (59.26)e Paymentb $.00 10.00 10.00 10.00 10.00 10.00 10.00 10.00 10.00 10.00 10.00 9.02 (9.32)e $109.02 (109.32)e Finance Chargec $.00d 1.50 1.37 1.24 1.11 .98 .84 .84 .57 .42 (.50)e .28 (.50)e .00f (.00)e $9.02 (9.32)e 15.2% (15.73%) a Assuming that a purchase of $ 100 is made on an account on Jan. 1 with no previous balance and a billing date the last day of the month. b Assuming that a minimum payment of $10 is made on the last of each month except for January. No payment is made during January-prior to receipt of initial statement. Timing of the payment does not affect the Annual Percentage Rate to some extent. c Calculated by multiplying a rate of 1 ½% times the previous month's ending balance. d There is no finance charge when an account starts the billing period with no previous balance. e These figures apply if a $.50 minimum monthly charge is used. f There is no finance charge when an account is paid in full. g Sum of the unpaid balances for each month divided by 12. h The total dollar finance charge for the period divided by the average monthly balance. 107 TABLE 6-5 AN ILLUSTRATION OF THE TOTAL FINANCE CHARGE REVENUE AND ANNUAL PERCENTAGE RATE ON A REVOLVING ACCOUNT AT A MONTHLY CHARGE OF 11/2%, AVERAGE DAILY BALANCE Month January February 15 February 28 March 16 March 31 April 16 April 30 May 16 May 31 June 16 June 30 July 16 July 31 August 16 August 31 September 16 September 30 October 16 October 31 November 16 November 30 December 16 December 31 Total Average monthly Balanceh Annual percentage ratei Unpaid Balancea $100.00 90.00 91.43 81.43 82.71 72.71 73.87 63.87 64.89 45.78 55.78 45.78 46.53 36.53 37.15 27.15 27.63 (27.65)f 17.63 (17.65)f 17.96 (18.15)f 7.96 (8.15)f 8.15 (8.65)f .00 (.00)f .00 (.00)f --- Paymentb $.00 10.00 --10.00 --10.00 --10.00 --10.00 --10.00 --10.00 --10.00 --10.00 --10.00 --8.15 (8.65)f --108.15 (108.65)f Average daily Balancec $100.00 --95.00 --85.58 --77.07 --68.15 --59.38 --50.19 --41.01 --31.84 --22.24 (22.25)f --12.80 (12.90)f --3.85 (3.94)f 647.11 (647.31)f $53.93 (54.94)f Finance Charged $.00e --1.43 --1.28 --1.16 --1.02 --.89 --.75 --.62 --.48 (.50)f --.33 (.50)f --.19 (.50)f --.00g (.00)f 8.15 (8.65)f 15.11% (16.04%)f a Assuming that a purchase of $100 is made on an account on January 1, with no previous balance and a billing date the last day of the month. b Assuming that a minimum payment of $10 is made on the 1 6th of each month (except for February) or near the middle of the billing period; no payment is made during January prior to receipt of initial statement. c Calculated by taking the sum of each day's unpaid balance (exclusive of unpaid finance charges) and dividing by the number of days in the billing period. d Calculated by multiplying a monthly rate of 1 ½% times the average daily balance. e There is no finance charge when an account starts the billing period with no previous balance. f These figures apply if a $.50 minimum monthly charge is used. g There is no finance charge when an account is paid in full. h Sum of the average daily balances for each month divided by 12. i The total dollar finance charge for the period divided by the average daily balance. 108 TABLE 6-6 AN ILLUSTRATION OF THE TOTAL FINANCE CHARGE REVENUE AND ANNUAL PERCENTAGE RATE ON A REVOLVING ACCOUNT AT A MONTHLY CHARGE OF 11/2%, ADJUSTED BALANCE METHOD Month January February March April May June July August September October November December Total Average monthly Balance Annual percentage Rate Unpaid Balancea $100.00 100.00 91.35 82.57 73.66 64.61 55.43 46.11 36.65 27.05 (27.15)f 17.61 (17.65)f 7.42 (8.14)f $702.16 (703.33) $58.51 (58.61)f Paymentb Adjusted Balancec $.00 $.00 10.00 90.00 10.00 81.35 10.00 72.57 10.00 63.66 10.00 54.61 10.00 45.43 10.00 36.11 10.00 26.65 10.00 17.05 (17.15)f 10.00 7.31 (7.65)f f 7.42 (8.15) .00 (.00)f $107.42 (108.15) --- Finance Charged $.00e 1.35 1.22 1.09 .95 .82 .68 .54 .40 (.50)f .26 (.50)f .11 (.50)f .00g (.00)f $7.42 (8.15)f 14.68% (13.9%)f a Assuming that a purchase of $100 is made on an account on January 1, with no previous balance and a billing date the last day of the month. b Assuming that a minimum payment of $10 is made on the last day of each month except for January (no payment is made prior to receipt of first statement). Timing of the payment does not affect the amount of the finance charge for the month, but could affect the Annual Percentage Rate to some extent. c Adjusted balance is the previous unpaid balance less the payment made. d Calculated by multiplying a rate of 1%% times the adjusted balance. e There is no finance charge when an account starts the billing period with no previous balance. f These figures apply if a $.50 minimum monthly charge is used. g There is no finance charge when an account is paid in full. h Sum of the unpaid monthly balances divided by 12. i The total dollar finance charge for the period divided by the average monthly balance. TABLE 6-7 OPINION AS TO DOLLAR FINANCE CHARGE ON REVOLVING ACCOUNT AT 18% AS RELATED TO KNOWLEDGE OF ANNUAL PERCENTAGE RATE Knowledge of rate N Estimated Dollar Finance Charge For a Less $10.00 $12.50 $18 More than to to than $10 $12.49 $17.99 $18 8.6% 10.8% 5.9% 58.1% 9.7% Year No Answer Percent of Total Knew 18% and 12% 186 33.8% 7.0% On balances above $500 Knew 18% only 126 22.9 7.1 10.3 4.8 54.8 12.7 10.3 Knew neithera 238 43.3 8.0 17.6 7.1 19.3 12.2 35.7 Total 550 100.0% 8.2% 13.6% 6.2% 40.5% 11.3% 20.2% a Includes those respondents reporting incorrect rates, those checking "Don't Know" on the questionnaire, and those who did not answer the question. 109 Of those respondents who paid no finance charges during the year, 8.6% reported the correct dollar cost. This is a greater level of awareness than that existing among families incurring finance charges of $12 or more during the year. Knowledge of dollar cost was greatest among families which incurred finance charges of between $3 and $12 over the year. There was a tendency (see Table 6-8) among families incurring greater charges to estimate larger dollar costs. For example, over 15% of the families who paid $24 in charges estimated a dollar finance charge of more than $18, a higher percentage than for any other group. CUSTOMER OPINIONS REGARDING FAIRNESS OF RATE OF CHARGE After asking the customer his opinion of the dollar finance charge cost of financing a purchase of $ 100 for 12 months on a department store charge account, an attempt was made to determine his attitude regarding the fairness of this charge by asking the following question: Do you consider this amount to be a fair charge for such credit? Yes________ No_______ No Opinion_______ TABLE 6-8 OPINION AS TO DOLLAR FINANCE CHARGE ON REVOLVING ACCOUNT AT 18% AS RELATED TO ANNUAL FINANCE CHARGES ACTUALLY INCURRED Annual dollar Finance charges Incurred $.00 $.01 to 2.99 $3.00 to 11.99 $12.00 to 23.99 $24 or more Total N 152 102 102 64 130 550 Percent of Total 27.6% 18.5 18.5 11.6 23.6 100.0% Estimated Dollar Finance Charge For a Year Less $10.00 $12.50 $18 More No than to to than Answer $10 $12.49 $17.99 $18 8.6% 11.2% 6.6% 34.2% 9.2% 30.3% 9.8 11.8 2.9 47.1 9.8 18.6 13.7 14.7 5.9 43.1 9.8 12.7 7.8 17.2 7.8 45.3 12.5 9.4 2.3 15.4 7.7 38.5 15.4 20.8 8.2% 13.6% 6.2% 40.5% 11.3% 20.2% As shown in Table 6-9, some 30% of the respondents either did not express an opinion or did not answer this question. Of those expressing an opinion, however, twice as many felt that the amount of charge was not fair. Opinion Regarding Fairness as Related to Income and Education Among income groups, the percentage of respondents thinking the amount of charge was fair was lowest among families with incomes of $7,500 or less, $15,001 to $20,000, and $20,001 to $25,000 (see Table 69). The largest percentage of "fair" opinions came from families with incomes of $25,001 or more. A negative opinion was most prominent among families with incomes of between $15,001 and $25,000. A large percentage of families with incomes below $10,000 did not answer the question at all, which perhaps significantly reduced both positive and negative opinions. Among education levels, variation in percentage of "fair" opinions was small-ranging from 14.9% (Some High School) to 25% (Grade School). Most of the education groups had about 20 to 25% positive opinions. The largest occurrence of negative opinions came from families in the Some Post-Graduate, Some College, and Advanced College Degree groups, ranging from 50 to 57.9%. 110 TABLE 6-9 OPINION AS TO FAIRNESS OF FINANCE CHARGES ASSESSED AS RELATED TO HOUSEHOLD INCOME AND EDUCATION Category Household incomea $7,500 or less 7,501 – 10,000 10,001 – 15,000 15,001 – 20,000 20,001 – 25,000 25,001 or more Total Educationb Grade school Some high school High school graduate Some college Undergraduate college Degree Some postgraduate Advanced college Degree Total Opinion as to Yes, was fair No, not fair Fairness No answer No Opinion N Percent of Total 52 54 146 129 69 88 538 9.5% 9.8 26.5 23.5 12.5 16.0 97.8% 17.3% 27.8 26.7 17.8 20.3 29.5 23.3% 25.0% 27.8 48.6 58.1 55.1 46.6 46.4% 57.7% 44.5 24.7 24.0 24.6 23.8 30.4% 24 47 148 123 86 4.4% 8.5 26.9 22.4 15.6 25.0% 14.9 25.7 23.6 24.4 16.7% 40.4 42.6 50.4 48.8 58.3% 44.7 31.7 26.1 26.7 57 62 10.4 11.3 24.6 19.4 57.9 50.0 17.6 30.7 547 99.5% 23.3% 46.4% 30.4% a Omitting 12 respondents that did not answer the question concerning income. b Omitting three respondents that did not answer the question concerning education. Opinion Regarding Fairness as Related to Knowledge of the Annual Percentage Rate Among respondents reporting either knowledge of both the 18% and 12% rate or knowledge of the 18% rate only, there was little variation in the percentage expressing positive or negative opinions as to fairness (Table 610). Positive responses for these two groups ranged from 24.2% to 28.6%; negative opinions ranged from 54% to 59.7%. Respondents who had no rate knowledge at all reported fewer positive responses (119.7%) and also fewer negative opinions (32.8%) than those who had some rate knowledge. The percentage of "No Opinion" answers was much greater among those who had no rate knowledge. Because of the large number of nonresponses from those who had no rate knowledge, definitive conclusions as to whether or not knowledge of the rate of charge has any significant bearing on customer opinion on fairness are not warranted. 111 TABLE 6-10 OPINION REGARDING FAIRNESS OF FINANCE CHARGE ASSESSED AS RELATED TO KNOWLEDGE OF ANNUAL PERCENTAGE RATE Knowledge of rate N Percent of Total Knew 18% and 12% 186 33.8 On balances above $500 Knew 18% only 126 22.9 Knew neithera 238 43.3 Total 550 100.0% Opinion as to Yes, was fair No, not fair 24.2% 59.7% Fairness No answer No opinion 16.1% 28.6 19.7 23.3% 54.0 32.8 46.4% 17.5 47.5 30.4% a Includes those respondents reporting incorrect rates, those checking "Don't K now" on the questionnaire, and those not answering the question. Opinion Regarding Fairness as Related to Incurrence of Finance Charges It might be expected that opinions regarding fairness of finance charges depend on how often or to what extent the customer has incurred such charges. Available evidence does not support this proposition, however (see Tables 6-11 and 6-12). These data show that the percentage of negative opinions does not vary directly with frequency or amount of finance charges incurred. For those respondents who incurred no finance charges, the percentage of fair opinions was 19.7%, and their negative responses were 42.8%. Among those who incurred charges of $12 to $23.99 during the year the percentage of fair opinions was 26.6%; negative responses for this group amounted to 46.9% (Table 6-11). Likewise, respondents who incurred finance charges a total of 12 times during the year reported 29.6% fair opinions and 44.4% negative responses (Table 6-12). These data imply that the level of charges incurred does not adversely effect opinions as to fairness of charges. TABLE 6-11 OPINION AS TO FAIRNESS OF FINANCE CHARGES ASSESSED AS RELATED TO ANNUAL FINANCE CHARGES ACTUALLY INCURRED Annual dollar Finance charges Incurred $.00 $.01 to $2.99 $3.00 to $11.99 $12.00 to $23.99 $24.00 or more Total N 152 102 102 64 130 550 Percent Of Total 27.6% 18.5 18.5 11.6 23.6 100.0% Opinion as to Yes, was fair No, not fair 19.7% 26.5 22.5 26.6 23.8 23.3% 112 42.8% 45.1 49.0 46.9 49.2 46.4% Fairness No answer No opinion 37.5% 28.4 28.4 26.6 26.9 30.4% TABLE 6-12 OPINION AS TO FAIRNESS OF FINANCE CHARGES ASSESSED AS RELATED TO AVERAGE NUMBER OF MONTHS IN WHICH FINANCE CHARGES WERE INCURRED Average number Months finance Charges incurred 0 1 to 6 times 7 to 11 times 12 times Total N 152 187 76 135 550 Percent of Total 27.6% 34.0 13.8 24.5 100.0% Opinion as to Yes, was fair No, not fair 19.7% 23.0 19.7 29.6 23.3% 42.8% 50.8 46.1 44.4 46.4% Fairness No answer No opinion 37.5% 26.2 34.2 25.9 30.4% Opinion Regarding Fairness as Related to Customer Estimate of Dollar Finance Charge Cost of Revolving Credit It was noted earlier that neither knowledge of the annual percentage rate of charge nor actual incurrence of finance charges appears to be related to the customer's opinion as to fairness of the charge. Data in Table 6-13 indicate clearly, however, that the customer's opinion about the dollar cost of financing revolving credit purchases definitely is related to attitudes regarding fairness or unfairness. The percentage of fair opinions declines consistently as the customer's estimate of the dollar finance charge rises. For example, the charge was reported to be fair by 57.8% of those respondents who estimated the dollar cost to be less than $10, while of those reporting an estimated dollar cost of more than $18, only 16.1% considered the charges fair. Similarly, the percentage of negative opinions rises consistently (22.2% for those estimating less than $10 finance charge) as the estimate of dollar finance charge becomes greater (74.2% negative opinions among those reporting an estimated dollar cost of more than $18). These data imply that a campaign to improve customer opinions about the fairness of finance charges in retail credit should concentrate on educating customers regarding the real dollar cost as well as informing them of the annual percentage rate of charge. TABLE 6-13 OPINION AS TO FAIRNESS OF FINANCE CHARGES ASSESSED AS RELATED TO CUSTOMER ESTIMATE OF DOLLAR FINANCE CHARGE ON REVOLVING ACCOUNT AT 18% Opinion as to Fairness Estimated N Percent Yes, was fair No, not fair No answer Dollar finance Of No opinion Charge Total Less than $10 45 8.2% 57.8% 22.2% 20.0% $10 to $12.49 75 13.6 49.3 26.7 24.0 $12.50 to $17.99 34 6.2 38.2 47.1 14.7 $18 223 40.5 16.6 69.5 13.9 More than $18 62 11.3 16.1 74.2 9.7 No answer 111 20.2 4.5 7.2 88.3 Total 550 100.0% 23.3% 46.4% 30.4% 113 CUSTOMER OPINION AS TO WHAT A FAIR DOLLAR FINANCE CHARGE WOULD BE After asking about the fairness of the dollar finance charge estimated by the respondent, the next question was asked to determine what dollar finance charge would be considered fair, assuming that the respondent had indicated that his estimate of the actual cost of finance $100 over a period of 12 months was not fair. The question used to determine this was: If No, what amount of dollar finance charge would you consider to be a fair charge for such a credit purchase? The question was open-ended with space provided in which the respondent could enter a dollar figure. To obtain an overall impression of the opinion as to a fair dollar finance charge, data in Table 6-14 display the amounts given by the respondents. It should be noted at this point, that 128 customers reported that they considered the estimated actual finance charge to be a fair one. Their answers are included in this table along with the opinions given by those respondents (225) who reported that their estimate of the actual finance charge was not fair. Overall, as indicated in Table 6-14, the most common charge determined to be "fair" was $9to $10(cited by25.3%of the respondents). An addition 21.6% reported amounts greater than $10 as being fair, whereas just under 20% cited various amounts of less than $9 as being fair. TABLE 6-14 OPINION AS TO WHAT DOLLAR FINANCE CHARGE TO FINANCE $100 FOR ONE YEAR WOULD BE FAIR AS RELATED TO CUSTOMER'S OPINION REGARDING FAIRNESS OF FINANCE CHARGE ASSESSED Answer to Question concerning Fairness Yes, was fair No, not fair No answer No opinion Total N 128 255 167 Percent of Total 23.3% 46.4 30.4 550 100.0% Estimate of Fair charge, Totala Less than $9 $9 to $10 More than $10 No answer 15.6% 32.2 2.4 23.4% 42.7 --- 57.0% 18.0 --- 3.9% 7.1 97.6 19.3% 25.3% 21.6% 33.8% a Includes two types of respondents: those reporting their estimate of the actual finance charge as being a fair one and those reporting their estimate of the actual charge to be unfair, and then, citing what they considered to be fair. In contrasting the two groups (i.e., those reporting the original estimate of the actual finance charge to be a fair one as opposed to those citing the estimate as being unfair), a major difference is evident. Among those who reported the original estimate as being fair, 57% had listed an amount of greater than $10. Similar amounts were given by only those who had reported their estimate to be unfair. On the other hand, less than $9 was cited as a fair charge much more often (32.2%) by those thinking the charge was unfair than by those who were of the opinion that the charge was fair (15.6%). To appreciate fully the significance of these data, it is necessary to have a clear understanding of the dollar finance charge actually generated on a revolving credit account over a period of a year when the nominal annual percentage rate is 18%. Depending upon the billing method used (see Tables 6-4, 6-5, and 6-6), $100 financed for 12 months with regular monthly payments and no additional purchases on the account produces a total finance charge ranging from $7.42 (Adjusted Balance method with no minimum monthly charge) to $9.32 114 (Previous Balance method with $.50 minimum monthly charge). The method in effect on the accounts used in this study produces the latter figure-$9.32. Thus, although some 46.4% of the respondents thought the dollar finance charge imposed was not fair, only 32.2% of those reported a fair charge, as being less than $9. Thus, a reason for the large percentage of respondents considering the finance charge to be unfair is that they have overestimated the actual dollar cost through a misunderstanding of how rates of charge work. If customers were more accurately informed about the real dollar finance charges involved, the likelihood of more favorable opinions on fairness would be enhanced. This fact, as mentioned in the previous section, is supported by the finding that among respondents who believed the dollar cost to be less than $10, almost 60% considered the charge to be fair (see Table 6-13). Only 22.2% of this group felt that such a charge was unfair. Customer Opinion as to What is a Fair Dollar Finance Charge as Related to Income and Education For most income groups, the level of finance charge considered to be fair for the largest percentage of the time was $9 to $10 as shown in Table 6-15. For the two highest income levels, however, as many or almost as many listed a figure of less than $9 as being fair as had listed $9 to $10. Two income groups (7,501 to $10,000 and $25,001 or more) listed a charge of more than $10 as being fair the greatest percentage of the time. Among education levels, as shown in Table 6-15, there is no consistent pattern. Families in the Grade School group listed less than $9 most often as being fair; two other groups (Some College and Some Post-Graduate) listed more than $10 most often. For the other four education levels, as true for the whole sample, a charge of $9 and $10 was listed. as being fair most often. Customer Opinion as to What is a Fair Dollar Finance Charge as Related to Knowledge of the Annual Percentage Rate It was indicated earlier that knowledge of the annual percentage rate of charge appeared to have little relation to customer opinions regarding the fairness of the dollar finance charge as they perceived it to be. The same conclusion is warranted concerning awareness of the rate and opinions as to a fair dollar charge. For those customers who were aware of both rates as well as for those who were aware of only the 18% rate, the most commonly cited fair charge was $9 to $ 10. Among those customers who did not know either rate, conclusions are not possible because of the relatively larger number who did not answer the question. Opinion as to What is a Fair Dollar Finance Charge as Related to Customer Estimate of Dollar Finance Charge at 18% The one factor which seems to have the most effect on the level of finance charges reported as being a "fair" charge is the respondent's own estimate of what he believes to be actual dollar cost of financing a purchase at 18%. Evidence indicates that this factor has much more influence than does awareness of the rate of charge, income, or education. To illustrate, data in Table 6-16 indicate clearly that the customer's own estimate of the dollar finance charge actually assessed is inversely correlated with the percentage of respondents reporting less than $9 to be the fair charge. Conversely, as the customer's own estimate of the dollar cost increases, the percentage of respondents reporting $9 to $10, and even more than $10, as being a fair charge increases consistently. Among respondents estimating the dollar finance charge actually assessed at 18% to be less than $10, 22.2% reported less than $9 to be "fair"; 2.2% reported $9 to $10 as being fair; none reported higher amounts (although 75.6% did riot answer the question). On the other hand, among respondents estimating the dollar finance charge at 115 18% to be over $18, only 11.3% reported less than $9 as being a fair charge, whereas 38.7% reported $9 to $10 as being fair and another 19.4% reported more than $10 as fair. TABLE 6-15 OPINION AS TO WHAT DOLLAR FINANCE CHARGE TO FINANCE $100 FOR ONE YEAR WOULD BE FAIR AS RELATED TO HOUSEHOLD INCOME AND EDUCATION Category Household incomev $7,500 or less 7,501 – 10,000 10,001 – 15,000 15,001 – 20,000 20,001 – 25,000 25,001 or more Total Educationc Grade school Some high school High school graduate Some college Undergraduate college Degree Some postgraduate Advanced college Degree Total Estimate of Fair charge, Yes, was fair No, not fair alla No answer No Opinion N Percent of Total 52 54 146 129 69 88 538 11.5% 7.4 17.8 20.9 29.0 20.5 19.3% 19.2% 16.7 28.1 27.9 29.0 23.9 25.3% 7.7% 24.1 23.3 21.7 18.0 30.7 21.6% 59.6% 50.0 30.8 29.5 23.2 26.1 33.8% 24 47 148 123 86 16.7 8.5 14.2 18.7 25.6 4.2% 31.9 27.0 23.6 25.6 12.5% 12.8 23.6 25.2 18.6 58.3% 46.8 34.5 31.7 30.2 57 62 24.6 22.6 26.3 27.4 28.1 19.4 19.3 30.6 547 19.3% 25.3% 21.6% 33.8% a Includes two types of respondents: those who said original estimate of the actual finance charge was fair and those who said original estimate was not fair but then listed an amount that they would consider to be fair. b Omitting 12 respondents that did not answer the question concerning income. c Omitting three respondents that did not answer the question concerning education. TABLE 6-16 OPINION AS TO WHAT DOLLAR FINANCE CHARGE TO FINANCE $100 FOR ONE YEAR WOULD BE FAIR AS RELATED TO CUSTOMER ESTIMATE OF DOLLAR FINANCE CHARGE ON REVOLVING ACCOUNT AT 18% Estimated N Percent Dollar finance Of Total Charge Less than $10 45 8.2% $10 to $12.49 75 13.6 $12.50 to $17.99 34 6.2 $18 223 40.5 More than $18 62 11.3 No answer 111 20.2 Total 550 100.00% Estimate of fair Chargea Less than $9 to $10 More than No answer $9 $10 22.2% 24.0 20.6 16.1 11.3 3.6 14.9% 2.2% 2.7 23.5 32.3 38.7 1.8 19.8% ------15.3% 19.4 --8.4% 75.6% 73.3 55.9 36.3 30.6 94.6 56.9% a Restricted to those customers who indicated that their estimate of the actual dollar finance charge on $100 at 18% APR was not fair and, then, listed what they considered to be a fair charge. 116 MAJOR PROBLEMS IN CUSTOMER AWARENESS Improving customer awareness and understanding of finance charges and revolving credit characteristics involves three distinct problems: (1) assuring that customers have an accurate knowledge of the annual percentage rate of charge, (2) determining that customers are able to translate accurately a given annual percentage rate of charge into a meaningful dollar and cents cost figure, and (3) instilling certain basic economic concepts and facts underlying the determination of rate limits. Of these three areas, the first is probably the easiest to accomplish and the one in which most progress has been made. The enactment of Truth in Lending legislation in 1969 has contributed to this improvement. Solution of the remaining two problems, however, is far from accomplished. Clearly, a large majority of credit users, although they may be aware of a given annual percentage rate , are not able to translate the APR into an accurate dollar and cents figure. If the APR is stated to be 18%, many assume that this means the cost of financing $100 for a year will be $18 even though monthly payments are made on the account, thereby reducing the balance on which the charge is computed. Perhaps this misunderstanding is a result of the longstanding practice before Truth in Lending became effective of stating finance charges as an "add-on" rate-that is, of basing the amount of the finance charge on the original amount financed for the life of the contract(thus, 5% "add-on" meant $5 per $100 financed per year). This is the cause of this misunderstanding, then the passage of time may eliminate the difficulty. However, nothing in Truth in Lending law at present will be of much value in teaching customers the dollars and cents meaning of an annual percentage rate. ATTITUDES TOWARD CHANGES IN BILLING PRACTICES Much attention has been directed since 1972 to various types of billing practices. Legislation has been introduced, as mentioned earlier, to prohibit certain methods of assessing finance charges, to facilitate correction of billing errors, to lengthen the credit period by requiring early mailing of statements, and so on. One of the objectives of this study was to determine what problems in the area of billing practices were perceived by customers in use of their revolving credit accounts. The question used to determine attitudes on this subject was as follows: Are there any billing practices of credit card issuers that you would like to see changed? Yes_______ No_______ If yes, please explain. The question was open-ended and space was provided for writing in answers to encourage respondents to mention any problems at all that were of concern to them. Of the 550 responding to the demographic questionnaire, 517 (94%) answered this question. Of the 517, 147 (28.4%) reported that they would like to see some changes in billing practices. The vast majority (71.6%) of those answering the question reported no need for changes. This implies that there were no important problems for most of the customers. As indicated in Table 6-17, the most frequent complaint cited by those indicating a desired change was that the rates of finance were too high (21, or 3.8% of the total sample reported this). The next most common suggested changes concerned use of the Previous Balance method of assessing finance charges and with delays in mailing statements, posting of payments, and so on with each category having 17 citations, or 3.1 % of total sample. Other changes suggested are shown with their frequency in Table 6-17. 117 It is noteworthy concerning the most frequently cited complaint-that is, rates too high-that five out of 21 of those reporting this fact actually paid no finance charges during the year. Another respondent concerned with rates, paid less than $3 in finance charges during the year. Concern over the Previous Balance method-the second most frequently cited complaint-evidently is more on the basis of general principle than actual dollar impact. Of the 17 respondents citing the Previous Balance method as a complaint, 8 of them paid no finance charges. For an additional 7 of these 17, the difference between the Previous Balance method and Adjusted Balance (least expensive possible method) would have amounted to $10 a month or less. For 1 customer out of the 17, the difference in method of assessing finance charges would have amounted to between $.26 and $.50 a month. An additional customer would have saved from $.51 to $.75 a month had Adjusted Balance instead of Previous Balance been used in determining charges. Thus the issue concerning billing method is clearly not a discernible problem to a large majority of customers, and when it is perceived to be a problem, it must be on the basis of something other than monetary impact. TABLE 6-17 TYPES OF BILLING PRACTICE CHANGES DESIRED Complaint Finance charge rates too high Previous balance method Bills not mailed in time to avoid charges, late fees, etc. Not clear as to when closing date is; desire specific time of month Slowness in posting purchases, delay in billing Difficulty in correcting billing errors Duplicate sales slips desired Description of item on bill desired Slowness in posting payments Forms too complicated Inability to change billing date to coincide with paycheck Too much trouble to write account numbers on return envelopes Personal photos desired on cards Dislike sales materials in bills Other miscellaneous complaints, none occurring more than 3 times N Percenta Of total Sample 21 3.8% 17 3.1 17 3.1 Percenta Of total Desiring change 14.3% 1.6 11.6 Percent Of total complaints 11.9% 9.7 9.7 12 2.2 8.2 6.8 11 2.0 7.5 6.3 11 10 9 8 5 4 2.0 1.8 1.6 1.5 0.9 0.7 7.5 6.8 6.1 5.4 3.4 2.7 6.3 5.7 5.1 4.5 2.8 2.3 3 0.5 2.0 1.7 2.0 2.0 28.5 1.7 1.7 23.9 3 0.5 3 0.5 42 7.6 Billing Practice Changes as Related to Income and Education Changes in billing practices became more of a concern as the income of the respondents increased (see Table 6-18). For example, less than 10% of the respondents with incomes of $7,500 or less reported complaints, while in the $25,001 or more group almost 40% desired one or more changes. Concern over the rates being too high was fairly well dispersed throughout all income levels, ranging from 5.5% to 2.3% (see Table 6-19). Families with incomes between $20,001 and $25,000 expressed the most 118 displeasure with the Previous Balance method(7.8%). It was of least concern to families with incomes of between $15,001 and $20,000 and $10,000 or less. Customer concern over "billing procedures" and "information on the bill" generally was greater among upper-middle and upper income levels (Table 6-19). In these categories were included such complaints as not mailing statements in time, slowness in posting purchases and payments, dislike of the closing dates, and desire for duplicate sales slips or a better description of merchandise on the statement. For all income groups, the single most pressing problem category reported was that of "billing procedures," with 9.8% of the respondents citing one or more instances of this type. The percentage of desired changes generally increased with the educational attainment (see Table 6-18). As with income, for all education groups the most frequently cited problem was "billing procedures." Concern over rates was greatest among Some Post-Graduate, Previous Balance was an issue most frequently to those in Undergraduate College Degree (see Table 6-19). TABLE 6-18 OPINION REGARDING CHANGES IN BILLING PRACTICES Category N Types of Response Percent Yes, changes No changes No answer of Total Desired Needed Household incomea $7,500 or less 52 9.5% 9.6% 82.7% 7,501 – 10,000 54 9.8 20.4 75.9 10,001 – 15,000 146 26.5 30.1 63.7 15,001 – 20,000 129 23.5 23.3 70.5 20,001 – 25,000 69 12.5 29.0 65.2 25,001 or more 88 16.0 39.8 58.0 Total 538 97.8% 26.7% 67.3% Educationb Grade school 24 4.4% 16.7% 83.3% Some high school 47 8.5 12.8 80.9 High school graduate 148 26.9 18.2 75.0 Some college 123 22.4 24.4 68.3 Undergraduate college 86 15.6 33.7 58.1 Degree Some postgraduate 57 10.4 47.4 45.6 Advanced college 62 11.3 38.7 61.3 Degree Total 547 99.5% 26.7% 67.3% a Omitting 12 respondents that did not answer the question concerning income. b Omitting three respondents that did not answer the question concerning education. 7.7% 3.7 6.2 6.2 5.8 2.3 6.0% --6.4% 6.8 7.3 8.1 7.0 --6.0% Billing Practice, Changes as Related to Number of Store Cards Held Predictably, the incidence of desired changes in billing practices increased with the number of department store credit cards held by the respondent. For example, as indicated by data in Table 6-20, the percentage of desired changes for families with eight or more credit cards (35.6%) was almost double that of families with only one or two cards (18%). 119 TABLE 6-19 OPINION REGARDING DESIRED CHANGES IN BILLING PRACTICES AS RELATED TO HOUSEHOLD INCOME AND EDUCATION Category N Percent of Total Type Rates too High of Complaint Previous Billing Information Solving Other Balance Procedures on Bill Billing Method Problems Household incomea $7,500 or less 52 9.5% 3.8% 1.9% 3.8% --7,501-10,000 54 9.8 5.5 1.9 7.4 1.9% 10,001-15,000 146 26.5 3.4 4.1 12.3 2.7 15,001-20,000 129 23.5 4.7 .8 7.8 3.1 20,001-25,000 69 12.5 4.3 7.2 10.1 7.2 25,001 or more 88 16.0 2.3 3.4 14.8 14.8 Total 538 97.8% 3.8% 3.1% 9.8% 4.9% Educationb Grade school 24 4.4% 4.2% 4.2% 8.3% --Some high school 47 8.5 6.4 ----2.1% High school 148 26.9 2.7 0.7 8.1 2.7 Graduate Some college 123 22.4 1.6 2.4 8.1 4.1 Undergraduate 86 15.6 4.7 8.1 11.6 5.8 College degree Some post57 10.4 7.0 5.3 17.5 12.3 graduate Advanced college 62 11.3 4.8 3.2 16.1 8.1 Degree Total 547 99.5% 3.8% 3.1% 9.8% 4.9% a Omitting 12 respondents that did not answer the question concerning income. b Omitting three respondents that did not answer the question concerning education. No answer or complaint ----2.7% 3.9 2.9 2.3 2.7% 5.8% 5.5 7.5 11.6 5.8 8.0 3.3% 90.4% 79.6 69.9 76.7 71.0 60.2 73.3% 4.2% --1.4 --6.4% 6.8 83.3% 75.9 81.8 .8 4.7 10.6 7.0 75.6 66.3 5.3 10.5 52.6 6.5 8.1 61.3 2.7% 3.3% 73.3% BILLING ERRORS AS REPORTED BY RESPONDENTS Widespread publicity has been given to complaints about billing errors and their correction. To ascertain the significance of such problems to revolving account users in Texas, the following question was asked: Have any of the credit card bills sent to you in the past year by the following types of credit card issuers contained mistakes? Respondents were then asked to identify the type of card(s) on which mistakes were made. The responses received to this question represent errors as perceived by the customer. All reported errors may not, infect, have been errors. No attempt was made to verify their occurrence. Error Experience as Related to Number of Store Cards Held As might be expected, the incidence of billing errors increased with the number of credit cards used by the respondent. For example, Table 6-21 shows that holders of eight or more department store credit cards reported almost twice as many (16.7%) department store card errors as those with only one or two store cards (8.7%). 120 Respondents reported a greater percentage (12%) of errors on store than on any other type. This is not unexpected, however, since this study is based on customers who had a revolving credit account at a department store. The second most often reported errors occurred with gasoline company credit cards (9.1 %). Bank cards contained errors for some 3.5% of the respondents. Other credit cards (including such cards as American Express, Diners Club, Carte Blanche, Air Travel Card) contained errors for only 2.4% of the respondents. TABLE 6-20 OPINION AS TO NEED FOR BILLING PRACTICE CHANGES AS RELATED TO NUMBER OF STORE CARDS HELD Type of Response Number of store N Percent of Yes, changes No changes No answer Cards held Total Desired Needed 1 or 2 150 27.3% 18.0% 76.7% 5.3% 3 to 5 238 43.3 28.6 66.4 5.0 6 to 7 72 13.1 27.8 65.3 6.9 8 or more 90 16.4 35.6 55.6 8.9 Total 550 100.0% 26.7% 67.3% 6.0% TABLE 6-21 BILLING ERROR EXPERIENCE IN RELATION TO NUMBER OF DEPARTMENT STORE CREDIT CARDS HELD Number of store N Percent of Cards held Total 1 or 2 150 27.3% 3 to 5 238 43.3 6 to 7 72 13.1 8 or more 90 16.4 Total 550 100.0% Percent reporting billing error from Dept. Store Bank card Gas Co. Other card 8.7% 12.2 12.5 16.7 12.0% 121 2.0% 2.5 2.8 8.9 3.5% 5.3% 10.1 9.7 12.2 9.1% 2.0% 1.7 1.4 5.6 2.4% TABLE 6-22 BILLING ERROR EXPERIENCE IN RELATION TO HOUSEHOLD INCOME AND EDUCATION Category Household incomea $7,500 or less 7,501-10,000 10,001-15,000 15,001-20,000 20,001-25,000 25,001 or more Total Educationb Grade school Some high school High school Graduate Some college Undergraduate College degree Some postgraduate Advanced college Degree Total Department Store Bank Card Gas Company Other Card Yes No N.A.c Yes No N.A. Yes No N.A. Yes No N.A. N Percent of Total 52 54 146 129 69 88 9.5% 9.8 26.5 23.5 12.5 16.0 3.8% 5.6 12.3 14.0 10.1 19.3 84.6%11.5% 83.3 11.1 83.6 4.1 82.9 3.1 79.7 10.1 77.3 3.4 538 97.8% 12.0% 81.5% 6.5% 3.5% 76.5% 20.0% 9.1% 80.5% 10.4% 2.4% 60.5%37.1% 24 47 4.4% 8.5 4.2% 14.9 83.3%12.5% --- 62.5% 37.5% --- 66.7% 33.3% --- 58.3%41.7% 76.6 8.5 2.1% 57.4 40.4 10.6% 78.7 10.6 --- 42.6 57.4 148 26.9 7.4 85.1 7.4 2.7 79.1 18.2 4.7 85.1 10.1 1.4$ 65.5 33.1 123 86 22.4 15.6 9.8 14.0 83.7 81.4 6.5 4.7 1.6 4.7 78.9 75.6 19.5 10.6 19.8 11.6 82.1 79.1 7.3 9.3 .8 3.5 61.8 37.4 57.0 39.5 57 10.4 17.5 75.4 730 8.8 80.7 10.5 19.3 71.9 8.8 5.3 61.4 33.3 62 11.3 21.0 77.4 4.8 83.9 11.3 83.9 9.7 6.5 64.5 29.0 547 99.5% 12.0% 4.6 1.9% 1.9 2.1 3.1 4.3 8.0 63.5% 34.6% 3.8% 76.9% 19.2% 1.9% 59.6%38.5% 63.0 35.2 11.1 74.1 14.8 --- 46.3 53.7 78.8 19.2 8.9 78.1 13.0 1.4 61.6 37.0 85.3 11.6 8.5 85.3 6.2 2.3 66.7 31.0 72.5 23.2 13.0 79.7 7.2 4.3 49.3 46.4 81.8 10.2 9.1 85.2 5.7 2.3 69.3 28.4 6.5 81.5% 6.5% 3.5% 76.5% 20.0% 9.1% 80.5% 10.4% 2.4% 60.5%37.1% a Omitting 12 respondents that did not answer the question concerning income. b Omitting three respondents that did not answer the question concerning education. c N.A. = no answer. Billing Error Experience in Relation to Income and Education As indicated by data in Table 6-22, the incidence of billing errors on department store cards and bank cards in particular increased with the level of income and education. For gasoline company cards and other cards, there is a tendency for greater incidence of error on incomes above $7,500, but the incidence of increase at higher incomes is not as consistent as the pattern evidenced by department store and bank cards. Overall, billing errors reported by respondents in this survey were significant enough to deserve attention, but the impact on the customers as a whole was relatively minimal and was confined to a small minority of card holders. 122 APPENDIX A DEMOGRAPHIC QUESTIONNAIRE 123 124 125 APPENDIX B RESULTS OF DEMOGRAPHIC QUESTIONNAIRE 126 127 128 129 130 131 132 133
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