JCB INTERNATIONAL CREDIT CARD CO., LTD. 
P. O. Box 71565, Los  Angeles, CA 90071-0565 
Cardmember Services (800) 366-4522 

Dear Cardmember: 

JCB CONSUMER CREDIT CARD AGREEMENT AND DISCLOSURE UNDER THE FEDERAL TRUTH IN LENDING ACT 

Before using the enclosed card, read this Agreement carefully.  This Agreement governs the Marukai Hawaii JCB Credit Card Account (“Account”) 
and the  Marukai  Hawaii  JCB  Card  (“Card”) that JCB International  Credit  Card  Co.,  Ltd. (“we”,  “us,”  or  “our”)  has  established  by  you.   By  signing, 
accepting or using the Card, you agree to all of the terms written below.  We thank you for choosing JCB. 

USE OF ACCOUNT.  You can use your Card to obtain cash, goods, or services.  You agree that you will use your Card primarily for personal, 

1. 
family or household purposes. 

Purchases.  You can use your Card to pay for goods and services at any and all merchant locations and service providers that honor the Card.  Any 
such use of your Card will be treated as a “purchase.” 

Cash Advance.  You can use your Card to obtain cash from branch offices of participating financial institutions or automated teller machines (“ATM”) 
linked to a participating ATM network.  Any such use of your Card will be treated as a “cash advance.” 

Convenience Checks.  We may, from time to time, issue convenience checks to you.  Convenience Checks allow you to write a check to a third party 
and the check is drawn against the Account.  Convenience Checks are treated the same as cash advances and are referred to in this Agreement as 
“check advances.” 

2. 
CREDIT LIMIT / CASH LIMIT.  You agree not to make purchases that result in your Account balance exceeding the credit limit we set for your 
Account.  You agree not to make cash or check advances that result in your Account balance exceeding the cash limit we set for your Account.  The 
initial credit limit is set forth on the face of your Card carrier.  The credit limit and the cash limit can be found on your monthly statement.  We reserve 
the right to reduce your credit limit or cash limit. 

3. 
PROMISE TO PAY.  You promise to pay us for all purchases, cash advances, interest charges, fees and other charges associated with your 
Account.  You also agree to be responsible for charges (i) incurred by persons who have actual, implied or apparent authority to use your Card(s) 
and/or Account or (ii) from which any of you receives benefit, whether tangible or intangible. 

4. 
PAYMENTS.  Each month you will be billed for charges to your Account.  You may elect to pay only a portion of the amounts owing on your 
Account  each  month,  but  you  agree to  pay  at  least the  Minimum  Payment  Due  by  the  Payment  Due  Date shown on  your  billing statement.    The 
Minimum Payment Due will be 3% of the New Balance shown on your billing statement or $15 (whichever is greater), plus any part of the previous 
month’s Minimum Payment Due that is past due, and any amount by which your New Balance exceeds your assigned credit limit.  A New Balance of 
$15 or less must be paid in full. 

Payments 1) received by 5 p.m. local time at the address shown on the remittance coupon on the front of your billing statement; 2) paid with 
check  or  draft  drawn  in  US  dollars  on  a  U.S.  financial  institution  or  a  U.S.  dollar  money  order;  and  3)  sent  in  the  return  envelope  with  only  the 
remittance coupon from your billing statement, will be posted on the same business day of the receipt.  Payments received after 5 p.m. local time at 
the remittance address on any day including the Payment Due Date, but that otherwise meet the above requirements; will be credited as of the next 
business  day.    Any  other  payments,  credit  may  be  delayed  up  to  five  days.    Payments  received  with  post-dated  checks  will  be  deposited  upon 
receipt. 

The Payment Due Dates for your Account will always fall on the same date each month and you have 27 days from your Statement Closing Date 
until the next Payment Due Date. If your due date falls on a weekend or holiday, your payments received on the next business day will be credited to 
your Account as received on the due date without late penalties. 

We can  accept  late  payments  and  partial  payments  marked “Payment  in  Full”  (or  similar  language)  without  losing  our  rights  including  the  right to 
obtain full payment of the amount owed on your Account.  

Payment by third party check or draft that has been endorsed by you to us is not acceptable.  Payment by check or draft made directly to us but 
drawn by anyone other than you may be rejected at our option. 

How we apply your payments: The minimum payment is applied at our discretion.  Any payments that exceed the Minimum Payment Due, are 

applied to the balance with the highest interest rate first. 

FOREIGN  TRANSACTIONS.    If  you  use  the  Card  for  a  transaction  in  a  currency  other  than  U.S.  dollars,  we  and  our  affiliate  company  will 
5. 
convert such transaction amount into U.S. dollars pursuant to the then-applicable conversion procedures and operating regulations.  Currently, we 
and our affiliate company use wholesale exchange rates, with the exception of certain currencies where there are government-mandated exchange 
rates.  In each case, such applicable rate will be increased by 1.1% by our affiliate company as an exchange fee and we will bill you for the U.S. 
dollar amount so calculated.  If a credit is issued for a transaction, the credit amount will be calculated in the same manner.  The currency conversion 
rate used on the conversion date may differ from the rate in effect on the date you transact on the Card or the date on which such transaction is 
posted.  You agree to accept such converted amount in U.S. dollars. 

VARIABLE  RATE  INFORMATION.    If you carry a balance or transact Cash or Check Advances on your Account, we will charge interest at 

6. 
your VARIABLE ANNUAL PERCENTAGE RATE (APR).  

The  VARIABLE  ANNUAL  PERCENTAGE  RATE  may  change  quarterly  on  the  first  day  of  the  billing  cycle  beginning  in  April,  July,  October,  and 
January, based on the Prime Rate on the second Tuesday on March, June, September, and December.  Any increase will have the effect of higher 
monthly  payments  and  higher  interest  charges.    If  The  Wall  Street  Journal  stops  publishing  the  Prime  Rate,  we  reserve  the  right  to  choose  a 
comparable index. 

The  VARIABLE  ANNUAL  PERCENTAGE  RATE  is  equal  to  9.9%  above  the  Prime  Rate.  This  applies  to  purchases,  cash  and  check  advances 
shown on your statement.  This VARIABLE ANNUAL PERCENTAGE RATE shall not exceed 18.0%. The INTEREST  CHARGE is posted to your 
Account at the end of the billing cycle in a single amount as part of the New Balance. As of September 8, 2009, the applicable Prime Rate is 3.25%.   

INTEREST  CHARGE  CALCULATION.    Interest  charge  on  purchases  and  interest  charge  on  cash  or  check  advances  are  calculated 

7. 
separately. We use a method called “average daily balance (including new purchases)” as follows: 

PURCHASE BALANCE SUBJECT TO PERIODIC INTEREST CHARGE:  If you pay your New Balance at the beginning of a billing cycle in full by the 
Payment Due Date, no Periodic Interest Charges will be imposed on purchase transactions for the billing cycle.  For balances not paid in full, we will 
determine the daily purchase balance by (a) starting with the day’s beginning purchase balance for the Account, (b) adding any purchases or other 
charges posted that day, (c) subtracting any payments or credits posted that day, and (d) subtracting any outstanding cash and  check advances, 
Interest Charges or Account fees, (e) dividing the sum of (a) to (d) by the number of days in the billing cycle. 

CASH AND CHECK ADVANCE BALANCE SUBJECT TO PERIODIC INTEREST CHARGES:  We  will determine the cash and check advance 
balance subject to periodic Interest Charges by (a) starting with the day’s beginning cash balance for the Account, (b) adding any cash and check 
advances, (c) subtracting any payments or credits posted that day, and (d) subtracting any outstanding purchases, Interest Charges or Account fees, 
(e) dividing the sum of (a) to (d) by the number of days in the billing cycle. 

Transaction Interest Charge.  Each time you obtain cash or check advance, you agree to pay an INTEREST CHARGE of $2.00 or 2% of the amount 
of  the  advance,  whichever  is  greater.    The  assessment  of  a  cash  or  check  advance  Interest  Charge  may  increase  the  VARIABLE  ANNUAL 
PERCENTAGE RATE on your periodic statement above the corresponding VARIABLE ANNUAL PERCENTAGE RATE. 

Grace Period For Purchases.  We will not assess a Periodic Interest Charge on purchases in a billing cycle if we receive the New Balance shown on 
your previous billing statement by the Payment Due Date (which is twenty-seven (27) days after the closing date of the billing cycle).  If we do not 
receive the entire New Balance by the Payment  
Due  Date,  Periodic  Interest  Charges  will  accrue  on  all  purchases,  from  the  beginning  of  the  billing  cycle  or  the  date  they  were  posted  to  your 
Account, whichever is later. 

No  Grace  Period  For  Cash  and  Check  Advances.    There  is  no  grace  period  for  cash  and  check  advances.    Periodic  Interest  Charges  accrue  on 
advances from the date they are posted to the Account. 

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8.  OTHER FEES AND CHARGES.  

Annual Fee.  We will waive all annual Credit Card fees for your Account until you are notified otherwise. 

Late Charge Fee.  You will have at least twenty-seven (27) days between the Billing Cycle Closing Date and the Payment Due Date shown on your 
billing statement.  If we do not receive the Minimum Payment Due within two days after the Payment Due Date, you agree to pay a late charge up to 
$15.00 is imposed for the billing period. 

No Over-limit Fee. No overlimit fee is assessed on your Account. However, please note that we may decline any transaction that may cause you to 
exceed your credit limit. 

Dishonored Check Charge.  You agree to pay up to $15.00 for each dishonored check or money order presented to us for payment for the billing 
period. We reserve the right to impose the interest charge for the billing period in accordance with the Agreement for the payment amount that was 
not processed. 

Service Charges.  If you request a duplicate statement or copy of any sales  draft or other document concerning any charge reflected on a billing 
statement, we will supply copies for $5.00 each, payable in advance.  If you request information that requires research, a fee of $15.00 per hour will 
be charged to your Account.  However, if any request for copies or research is made to dispute a charge on the Account, and it turns out the charge 
was in error, we will credit the Account for any service charges imposed. 

Collection Costs.  You agree to pay the costs of collecting the Account or retrieving the Card, including court costs and reasonable attorneys’ fees 
and costs, whether or not a lawsuit is filed. 

Fees Related to Method of Payment. 
such repayment is made by mail, electronic transfer, telephone authorization, or other means, unless such payment involves an expedited service by 
us to avoid late charges. 

 We will not impose a separate fee to allow you to repay an extension of credit or Interest Charge, whether 

The above fees and charges will be assessed to the extent permitted by applicable law. 

EQUAL  CREDIT  OPPORTUNITY  ACT  NOTICE.  The  federal  Equal  Opportunity  Act  prohibits  creditors  from  discriminating  against  credit 
9. 
applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided the applicant has the capacity to enter into a binding 
contract);  because  all  or  part  of  the  applicant’s  income  drives  from  any  public  assistance  program;  or  because  the  applicant  has  in  good  faith 
exercised any right under the Consumer Credit Protection Act.  

10.  CREDIT  BALANCE. If  a credit  balance (represented  by  an amount  with  a minus  “-“  sign)  is  shown  on  your  statement,  it  represents  money 
owed to you.  If you do not make sufficient charges against the credit balance or request a refund, we will issue a check to you for the credit balance 
if the amount is $1.00 or more within 30 days after expiration  of the six month period following the date of the first statement indicating the credit 
balance.  To obtain a refund of a credit balance, please write to us at JCB International Credit Card Co., Ltd., 700 S. Flower Street, Suite 1000, Los 
Angeles, CA 90017. 

11.  FINANCIAL DATA AND CREDIT INFORMATION.  You agree to give us a current financial statement or new credit information, from time to 
time,  upon  request.    From  time  to  time  we  may  release  information  about  our  experience  with  you  and  your  credit  records  to  credit  bureaus  and 
others.    We  can  reinvestigate  any  information  you  provided  on  your  application  at  any  time,  and  in  the  course  of  doing  so  we  may  ask  you  for 
additional information, request credit bureau reports and otherwise verify your credit standing. 

12.  CHANGE OF PERSONAL INFORMATION.  You agree to notify us immediately of any change in your name or address.  Your notice must be 
sent to us at the address appearing on the front of your statement. 

13.  UNAUTHORIZED USE.  You agree to contact us by telephone immediately if someone uses your Card without your permission or if your Card 
is lost or stolen.  You can call toll-free, twenty-four (24) hours a day, at: 800-366-4522. 

You  may  be  liable  for  the  unauthorized  use  of  your  Card.    You  will  not  be  liable  for  unauthorized  use  that  occurs  after  you  notify  us,  orally  or  in 
writing, of the loss, theft, or possible unauthorized use. In any case, your liability will not exceed $50.00. 

14.  MERCHANT RELATIONS.  We will not be responsible if any merchant or financial institution refuses to honor your Card.  If you  
have a dispute concerning any merchandise or service purchased using your Account, you agree to attempt to resolve the dispute directly with the 
merchant.  We will not be responsible for errors in cash advance transactions that are due to malfunctions in ATMs. 

15.  AUTHORIZATIONS.    We  reserve  the  right  to  deny  authorization  of  any  purchase  or  cash  or  check  advance  transaction  without  prior 
notification. You agree that neither we nor any merchant or authorization service we use, shall be liable for any authorization denial. 

16.  TERMINATION OF ACCOUNT. 

Termination By You.  You may terminate your Account at any time by returning all current Card(s) to us and writing us that you wish to cancel the 
Account.  Your letter and the Card(s) must be sent to us at JCB International Credit Card Co., Ltd., 700 S. Flower Street, Suite 1000, Los Angeles, 
CA 90017. 

Termination By Us.  We may terminate your Account at any time, with or without cause, upon giving you only such notice as is required by law.  If we 
terminate your Account, you must immediately return all Card(s) and Convenience Check(s) to us.  Any use of Card(s) or Convenience Check(s) 
after your Account has been terminated may be considered fraudulent.  Terminating the Account does not require you to immediately pay off the 
remaining balance. 

If you or we terminate your Account, you will still be responsible for charges to your Account, even if they are made or processed after your Account 
is closed.  You will be responsible to pay the outstanding balance on your Account according to the terms of this Agreement. 

17.  CARD  SURRENDER.  You agree to surrender such Card to us or to our agents upon demand, and to promptly cease use of and return all 
Cards and Convenience Checks upon termination of your Account. 

18.  LIABILITY.  If you applied for an Account as an individual and were approved, then your Account is an individual Account.  If you applied for an 
Account with another person as a joint Account and were approved, then your Account is a joint Account.  If you requested that an additional person 
be given a Card to use your Account (whether the Account is an individual Account or a joint Account), and we issued you an additional Card for that 
person, then that person is an Authorized User.  If your Account is an individual Account, you are liable for the full amount of all purchases, cash and 
check  advances,  Interest  Charges,  miscellaneous  charges  and  fees,  and  any  other  monetary  obligations  associated  with  the  Account,  including 
charges in excess of your credit limit and including any charges by an Authorized User.  If your Account is a joint Account, each of you has the right 
to use the Account to the extent of the credit limit and each of you is jointly and severally liable for the full amount of all purchases, cash and check 
advances, Interest Charges, miscellaneous charges and fees, and any other monetary obligations associated with the Account, including charges in 
excess of your credit limit and including any charges by an Authorized User or by the joint applicant on your joint Account. 

19.  WAIVERS.    We  may  waive  or  decline  to  enforce  any  of  our  rights  under  this  Agreement  at  any  time  without  affecting  our  ability  to  enforce 
those same rights at another time.  Our ability to enforce our remaining rights is not affected if we waive any of our rights. 

20.  ELECTRONIC TERMINALS.  If you have been or are later  
given a Personal Identification Number (“PIN”) to access your Account at ATMs, you agree not to disclose your PIN to others.  You also agree that 
we may terminate your use of ATMs without cause or prior notice. 

21.  CHANGE  IN  TERMS.  We can change the terms of this Agreement, including terms relating to interest rates and fees that may be imposed 
and including adding new contract terms that differ in kind from the terms and conditions included in this Agreement, at any time.   

You will be notified of significant changes in terms of the Account, including interest rates and fees, not later than 45 days prior to the effective date. 
When certain terms change, you have the right to cancel the Account. Closing or canceling the Account does not require you to immediately pay off 
the remaining balance. You can also opt out of, or refuse, those changes before the effective date except your minimum payment due. Once you opt 
out of, or refuse those changes, 1) your Account may be closed, 2) JCB Cash Back Points Program may be cancelled and 3) Card benefits become 
unavailable. Please contact our Cardmember Services at 1-800-366-4522 for more information. 

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MHI-TILA (12-2010) 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
No increase in annual percentage rate (APR), fee, or Interest Charge on your credit card Account shall be effective before the end of the 1-year 
period beginning on the date on which your Account is opened. Changes in a variable rate that occur quarterly in the index are not included in this 
limitation. 

22.  ASSIGNMENT.  We  have  the  right  to  assign  all  or  any portion  of this  agreement and  the  outstanding  balance  of  your  Account  at any  time, 
without providing prior notice. 

23.  GOVERNING LAW/CONFLICTING TERMS.  The rights and obligations between you and us concerning the Account are governed by and 
interpreted according to California and federal law.  Your Account has been approved and agreed to in California, credit is extended to you in 
California, your payments are received in California, and your payments are completed when we actually receive collected funds in California from 
your payment check.  Any dispute between you and us will be decided under California law.  The terms of this Agreement supersede any conflicting 
terms set forth on any sales slip or advance document.  If any one or more parts of this Agreement is found to be unenforceable, the remainder of 
the Agreement will remain in full force and effect. 

24.  JCB  CASH  BACK.  Your Account is eligible to receive JCB Cash Back Points when the Card is used for purchase (but not cash advances, 
check  advances,  finance  charges,  and  other  fees  and  charges).    You  will  earn  three  JCB  Cash  Back  Points  for  every  $100.00  in  new  purchase 
transactions (net of purchases, chargebacks, and chargeoffs) at any Marukai establishment posted to your Account during a billing period.  You will 
also earn one JCB Cash Back Point for every $100.00 in new purchase transactions (net of purchases, chargebacks, and chargeoffs) at any other 
establishment posted to your Account during a billing period.  If your Account has at least ten JCB Cash Back Points outstanding on your Account 
monthly billing statement, you may redeem the JCB Cash Back Points in writing or by telephone.  You are entitled to receive $1.00 for every one 
JCB Cash Back Point redeemed, which will be credited to your Account. JCB Cash Back Points in one calendar year expire at the end of the next 
calendar year. JCB Cash Back Points in one calendar year expire at the end of the next calendar year. JCB Cash Back Points Redemption requests 
for closed or past due status Accounts will not be processed. 

25.  MARUKAI MEMBERSHIP.  You are required to remain a legal resident of the State of Hawaii and to maintain your membership with Marukai 
Corporation  (“Marukai  membership”)  to  maintain  your  Account  and  Card.    Marukai  Corporation  currently  provides  the  Marukai  Hawaii  JCB  Card 
feature  of  membership  only  with  “regular”  Marukai  memberships  and  not  with  reduced-fee  “senior”  Marukai  memberships  unless  you  agree  to 
convert your reduced-fee “senior” Marukai membership to a regular-fee “regular” Marukai membership.  “Senior” Marukai membership privileges do 
not apply with the Marukai JCB Card program.  In the event that the termination of your Marukai membership is known to us, we reserve the right to 
replace your Account and Card with a JCB Silver Card Account.  You will receive a new Agreement which governs the JCB Silver Card Account and 
the JCB Silver Card.  Your Marukai membership is a Marukai Corporation program, and we have no control over or responsibility for the terms and 
conditions of your Marukai Corporation program.  Your Marukai membership will be subject to a separate agreement that you executed with Marukai 
Corporation.    The  anniversary  date  of  your  Marukai  membership  will  be  superseded  by  the  anniversary  date  of  your  Account.    The  Marukai 
Membership Charge that is assessed by Marukai Corporation on your Marukai membership will be billed to your Account beginning with your next 
anniversary date.  Marukai Corporation is not a party to this Agreement, does not participate in any extensions of credit under this Agreement, and 
has no authority to make any credit decisions or other decisions relating to the Account.  You authorize Marukai to verify your Marukai membership 
status with us, and you authorize us to notify Marukai if and when I become a Marukai Hawaii JCB Cardmember and in the event that you cease to 
be a Marukai Hawaii JCB Cardmember. 

YOUR FEDERAL BILLING RIGHTS 

This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. 

How To Notify Us In Case Of Errors Or Questions About Your Billing Statement. 

If you think there is an error on your statement, or if you want more information about a transaction on your billing statement, write 
to us as soon as possible at the address on your billing statement. 

We must hear from you no later than sixty (60) days after we sent you the first billing statement on which the error or problem appeared. You can 
telephone us, but doing so will not preserve your rights. 

In your letter, give us the following information: 

• 
• 
• 

Your name and Account number. 
The dollar amount of the suspected error. 
Describe the error and explain, if you can, why you believe there is an error.  If you need more information, describe the item you are not 
sure about. 

Your Rights And Our Responsibilities After We Receive Your Written Notice. 

We must acknowledge your letter within thirty (30) days, unless the error has been corrected.  Within ninety (90) days, we must either correct the 
error or explain why we believe the statement is correct. 

After receiving your letter, we cannot try to collect any amount you question, or report you as delinquent.  We can continue to bill you for the amount 
in question, including Interest Charges, and we can  
apply any unpaid amount against your credit limit.  You do not have to pay any portion of the amount in question while we are investigating, but you 
are obligated to pay the parts of your billing statement that are not in question. 

If we find that we made a mistake on your billing statement, you  will not be required to pay any Interest Charges related to any of the amount in 
question.    If  we  are  not  in  error,  you  may  have  to  pay  Interest  Charges,  and  you  will  have  to  make  up  any  missed  payments  on  the  amount  in 
question.  In either case, we will send you a statement of the amount owed and the date it is due. 

If you fail to pay the amount we think you owe, we may report you as delinquent.  However, if our explanation does not satisfy you and you write to 
us within ten (10) days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question about your statement, and 
we must tell you the name of anyone we reported you to.  When the matter is settled, we must tell anyone we report you to that the matter has been 
settled. 

If we don’t follow these rules, we cannot collect the first $50.00 of the amount in question, even if your bill was correct. 

Special Rule For Credit Card Purchases. 

If you have a problem with the quality of property or services that you purchased with a credit card, and you have tried in good faith to correct the 
problem with the merchant, you may have the right not to pay the remaining amount due on the property or services.  There are two limitations on 
this right: 

(a)  You must have made the purchase in your home state or, if not within your home state, within one hundred (100) miles of your current 

mailing address; and 

(b)  The purchase price must have been more than $50.00. 

These limitations do not apply if we own or operate the merchant, or if we mailed you the advertisement for the property or services. 

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MHI-TILA (12-2010) 

 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Interest Rates and Interest Charges 
Annual Percentage Rate (APR) for 
Purchases 

APR for Cash and Check Advances 
(including Balance Transfers) 
Paying Interest  

For Credit Card Tips from the 
Federal Reserve Board 

13.15%* 
This APR will vary with the market based on the Prime Rate 
13.15%* 
This APR will vary with the market based on the Prime Rate 
Your due date is at least 27 days after the close of each billing cycle.  
We will not charge you interest on purchases if you pay your entire 
balance by the due date each month.  We will begin charging interest 
on cash and check advances (including balance transfers) on the 
posted date. 
To learn more about factors to consider when applying for or using a 
credit card, visit the website of the Federal Reserve Board at 
http://www.federalreserve.gov/creditcard 

Fees 
Set-up and Maintenance Fees 

•  Annual Fee 
Transaction Fees 

$0.00 

•  Cash and Check Advance 

(including Balance Transfers) 

Either $2 or 2% of the amount of each cash or check advance 
(including balance transfers), whichever is greater 

•  Foreign Transaction 

1.1% on each transaction before conversion to U.S. dollars. 

Penalty Fees 

•  Late Payment 

Up to $15.00 

•  Over-the-Credit Limit 

$0.00 

•  Returned Check 

Up to $15.00 

How We Will Calculate Your Balance: 

We  use  a  method  called  “average  daily  balance 
(including new purchases).” 

The Prime Rate used to determine the APR is the rate published in The Wall Street Journal on December 
8, 2009, which was 3.25%.  The APR may change quarterly on the first day of the billing cycle beginning 
in  April,  July,  October  and  January,  based  on  the  Prime  Rate  on  the  second  Tuesday  of  March,  June, 
September and December.  The APR will not exceed 18.0%.   

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MHI-TILA (12-2010)