Variable Rate Credit Card  
Agreement and 
 Truth in Lending Disclosure 

In this Variable Rate Credit Card Agreement and Truth in Lending Disclosure (Agreement), the 
words you and your mean each and all of those who applied for the Card. Card means the Credit 
Card or Cards for which you applied and any duplicates or renewals we issue. Account means 
this open-end revolving line of credit account established pursuant to this Agreement. Charges 
are posted to the Account from the use of the Card, information from the Card or any other 
device or procedure by which the Account can be accessed. We, us and our mean Hudson Valley 
Federal Credit Union (HVFCU).  

RESPONSIBILITY  
You agree to repay all charges, purchases, cash advances and finance charges arising from the 
use of the Card and the Account. For example, you are responsible for charges made by yourself, 
your spouse, and minor children. You are also responsible for charges made by anyone else to 
whom you give the Card, and this responsibility continues until the Card is recovered. You 
cannot disclaim responsibility by notifying us, but we will close the Account for new 
transactions if you so request and return all Cards. Your obligation to pay the Account balance 
continues even though an agreement, divorce decree, or other court judgment to which we are 
not a party may direct you or one of the other persons responsible to pay the Account.  

If you have requested an authorized user on your Card, you agree to be responsible for all 
charges made by yourself and your authorized user. You understand the authorized user is not 
the person liable for debts incurred with the use of the Card, and that you are the person solely 
responsible for the Account.  

GOVERNING LAW 
This agreement is made in New York and shall be governed by the laws of the State of New 
York to the extent that New York law is not inconsistent with controlling Federal law. New 
York’s choice of law rules shall not be applied if that would result in the application of non-New 
York Law. 

CREDIT LINE  
We have established a revolving line of credit for you and will notify you of the credit limit 
when we issue the Card. You agree not to let the Account balance exceed this approved credit 
line. Each payment you make on your Account will restore your credit line by the amount of the 
payment, which is applied to principal. If you request an increase to your credit limit and we 
approve the request, your use of the Card constitutes acceptance of the increased line. By giving 
you written notice we may reduce your credit line, or with good cause, revoke your Card and 
terminate this agreement. Good cause includes your failure to comply with this agreement, or an 
adverse re-evaluation of your creditworthiness. You may also terminate this agreement at any 
time, but termination by either of us does not affect your obligation to pay the Account balance. 
The Card remains our property and you must recover and surrender to us all Cards upon our 
request and upon termination of this agreement.  

 
 
 
 
 
 
USING THE CARD  
You understand that the use of your Card will constitute acknowledgment of receipt and 
agreement to the terms of this Agreement.  

To make a purchase, you and any authorized user may use the Card by presenting it to a 
participating VISA merchant or provide the Card information for purchases not made in person. 
To make a cash advance, there are two alternative procedures to be followed. One is for you and 
any authorized user to present the Card to a participating VISA merchant, to us or to another 
financial institution, and sign the sales or cash advance draft which will be imprinted with your 
Card. The other is to complete the transaction by using your Personal Identification Number 
(PIN) in conjunction with the Card in an Automated Teller Machine (ATM) or other type of 
electronic terminal that provides access to the Visa system. You may make cash withdrawals that 
total $1000.00 per day either individually or in aggregate. This service may not be available at all 
machines. Dollar amounts available may vary between machines.  

INACTIVITY  
At the time your Card is due to expire, if your Account has been inactive for a period of 23 
months, we will not reissue another Card and your Account will be closed. You will then be 
required to re-apply and be re-qualified to use a Card. 

ISSUANCE OF PERSONAL IDENTIFICATION NUMBER  
We will issue you a Personal Identification Number (PIN) for use with your Card. This PIN is 
confidential and should not be disclosed to anyone. In the event a use of your PIN constitutes an 
electronic funds transfer, the terms and conditions of your Electronic Funds Transfer Disclosure 
& Agreement apply.  

LIABILITY FOR UNAUTHORIZED USE 
You may be liable for unauthorized use of your Card.  

You will not be liable for unauthorized use that occurs after you notify us of the loss, theft, or 
other unauthorized use. In any case, your liability will not exceed $50.00 for unauthorized cash 
advances at ATMs, and zero liability for unauthorized purchases made with your Card. In order 
to qualify for the zero liability, you must not have been negligent or fraudulent in the handling of 
the Account.  

In case of loss or theft, call the credit union immediately at 845-463-3011. 

MONTHLY PAYMENT 
We will mail you a statement every month showing your previous balances of purchases and 
cash advances, the current transactions on your Account, the remaining credit available under 
your credit line, the new balances of purchases and cash advances, the total new balance, the 
finance charge due to date, and the minimum payment required. Every month you must pay at 
least the minimum payment within 25 days of your statement closing date. You may pay more 
frequently, pay more than the minimum payment, or pay the total new balance in full, and you 
will reduce the finance charge by doing so. The minimum payment will be either (a) 2% of your 

 
 
  
 
 
 
 
 
total new balance, or $10.00, whichever is greater, or (b) your total new balance, if it is less than 
$10.00, plus (c) any portion of the minimum payment(s) shown on prior statement(s) which 
remains unpaid. In addition, at any time your total new balance exceeds your credit line, you 
must immediately pay the excess upon our demand. Payments made to your Account will be 
applied in the following order: fees, finance charges, purchases, and cash advances. We may 
accept checks marked “payment in full” or with words of similar effect without losing any of our 
rights to collect the full balance of your Account with us. 

FINANCE CHARGE 
HOW TO AVOID PAYING INTEREST ON PURCHASES: 
Your due date is at least 21 days after the close of each billing cycle. We will not charge you any 
interest on purchases if you pay your entire new balance by the due date each month. 

HOW WE WILL CALCULATE YOUR BALANCE: 
We use a method called “Average Daily Balance (including new purchases)”. 

HOW WE CALCULATE YOUR BALANCE AND INTEREST CHARGE ON BALANCES: 
We figure the interest charge on your Account by applying the applicable Periodic Rate to the 
“Balance Subject to Interest Rate” which is the “Average Daily Balance” of your Account for 
each feature category, including certain current transactions. Feature categories include 
purchases, balance transfers, cash advances and promotional balances. These calculations may 
combine different feature categories with the same “Monthly Periodic Rates”. The “Average 
Daily Balance” for each feature category is arrived at by taking the beginning balance of such 
feature category each day and adding any new transactions to the balance, except we will not 
include new purchases if you have paid in full the New Balance on your previous statement by 
the Payment Due Date or if the New Balance on your previous statement was zero. Cash 
advances incur an interest charge from the date they are posted to your Account. We then 
subtract any payments or credits and unpaid interest or other “Finance Charges” allocated to the 
feature category balance for the day. This gives us the daily balance for such feature category. 
The daily balances for such feature category are then added together and divided by the number 
of days in the billing cycle. The result is the “Average Daily Balance” for such feature category. 
The interest charge is determined by multiplying the “Average Daily Balance” by the monthly 
periodic rate.  If your periodic rate is computed using an index, your periodic rate(s) may vary. 
The Payment Due Date will be no less than 21 days after we have sent you your current monthly 
statement. For your Account to be considered current and to avoid a late payment fee, you must 
pay at least the Minimum Payment Due this period and any Past Due Amount by the due date 
shown on your statement. 

For all Cards, the current Monthly Periodic Rate and the corresponding  interest rate will be 
disclosed to you in a separate letter enclosed with this Agreement/Disclosure.   

VARIABLE RATE  
Your Account is subject to a Variable Rate. Your ANNUAL PERCENTAGE RATE (APR) 
may increase (or decrease) if our index, the Wall Street Journal Prime Rate in effect on the fifth 
to last business day of the month increases (or decreases). When a range of rates is published in 
the Wall Street Journal on that day, the index will be the highest rate. Each month, the new index 

 
 
 
 
 
 
 
 
 
rate is added to the margin (disclosed separately in the letter enclosed) to calculate the ANNUAL 
PERCENTAGE RATE. The ANNUAL PERCENTAGE RATE, when changed, affects your 
entire balance and is effective the first full statement cycle following the change in the Prime 
Rate. The ANNUAL PERCENTAGE RATE will never be more than NCUA’s rate ceiling. We 
will not accumulate unused index rate increases and decreases. Changes in the ANNUAL 
PERCENTAGE RATE will result in more (or fewer) payments. We may change the index with 
proper notice to you. 

In accordance with federal regulation, for Card balance transfers conducted in certain situations 
such as, changing from one product to another within this credit union, the amount of the 
transferred balance will remain at the variable ANNUAL PERCENTAGE RATE in effect for 
the product from which the balance was transferred. For example, if you wish to change from a 
Visa Platinum Rewards card to a Visa Platinum Card and this change results in transferring the 
balance remaining on the Visa Platinum Rewards Card to the Visa Platinum Card, the variable 
ANNUAL PERCENTAGE RATE of the Visa Platinum Rewards Card must remain in effect on 
the amount transferred until such time that portion of the balance is paid in full and all future 
transactions will be charged the variable ANNUAL PERCENTAGE RATE in effect for the 
Visa Platinum Card. This does not apply in situations when your Card requires replacement, for 
example if your Card is compromised, lost, stolen, etc. 

CHANGE IN TERMS 
We have the right to change any of the terms of this Agreement, including but not limited to 
rates and fees, at any time. You will be given notice of a change as required by applicable law. 
Any change in terms governs your Account as of the effective date, and will, as permitted by law 
and at our option, apply both to transactions made on or after such date and to any outstanding 
Account balance. We may amend the Annual Percentage Rate on your Account, based on the 
results of our obtaining and evaluating your credit information. Use of your Account may 
constitute agreement to any change in terms. 

RETURNS AND ADJUSTMENTS  
Merchants and others who honor the Card may give credit for returns or adjustments, and they 
will do so by sending us a credit, which we will post to your Account. If your credits and 
payments exceed what you owe us, we will hold and apply this credit balance against future 
purchases and cash advances, or if it is one dollar or more, refund it on your written request or 
automatically after 6 months.  

CASH ADVANCE FEE 
For each cash advance conducted in person at a branch, we will assess a cash advance 
transaction fee equal to 2% of the amount of the cash advance. Cash advance transaction fees 
will be added to the cash advance balance on your Account. 

FOREIGN TRANSACTIONS  
Purchases and cash advances made in foreign countries and foreign currencies will be billed to 
you in U.S. dollars. The conversion into dollars will be made in accordance with the operating 
rules for international transactions established by Visa, USA, Inc. and may occur on a date other 

 
 
 
 
 
than the date of the transaction; therefore, the currency conversion rate may be different than the 
rate in effect at the time of the transaction.  

We do not determine the currency conversion rate that is used nor do we receive any portion of 
the currency conversion rate. You agree to pay the converted amount.  

The exchange rate to dollars will be a rate that is in effect for the applicable central processing 
date and is selected either from the range of rates available in wholesale currency markets; or the 
government mandated rate. An International Transaction Fee of 1% of the transaction amount 
will be assessed and will be shown independently of the transaction on your billing statement.  

CONSENSUAL SECURITY INTEREST  
(Shares/deposits as Security) 
To  secure  performance  of  your  obligations  under  this  Agreement,  you  hereby  grant  us  a 
security interest in all individual and joint share/deposit account(s) that you may have with 
us from time to time and in any other money that we may owe you.  You understand and 
intend  that  by  reason  of  such  security  interest  here  granted,  we  may  satisfy  your 
indebtedness under this Agreement by charging your share/deposit account(s) maintained 
with us if you default in payment under the Agreement, without further notice to you.  This 
security interest does not apply to any Individual Retirement Account or any other account 
that would lose special tax treatment under state or federal law if given as security. 

CROSS COLLATERAL  
To secure your Account, you grant us a purchase money security interest under the Uniform 
Commercial Code (UCC) in any goods you purchase through the Account, except property used 
for personal, family or household purposes.  Any collateral securing other loans with us (other 
than your principal dwelling) will also secure advances made under this Agreement. If you 
default, we will have the right to recover any of these goods, which have not been paid for 
through our application of your payments in the manner described under the paragraph Monthly 
Payments, as provided in this Agreement.  

MERCHANT DISPUTES  
We are not responsible for the refusal of any merchant, financial institution, or automated 
equipment to honor or accept your Card.  

We are subject to claims and defenses (other than tort claims) as described under Your Billing 
Rights.  

DEFAULT 
You will be in default if:  
you fail to make any minimum payment within 25 days of your statement date;   
you fail to live up to the terms and conditions of this Agreement and Truth-in-Lending 

Disclosure;  

your creditworthiness is impaired;  
you die, become insolvent, or are the subject of bankruptcy or receivership proceedings;  

 
 
 
 
 
 
 
you have made a misrepresentation in connection with the Card application and/ or this 

Agreement, or;  

you are in default on any other loan with us.  

If you are in default, we have the right to terminate this Agreement and demand immediate 
payment of your full Account balance, subject to our giving you any notice required by law. To 
the extent permitted by law, you will also be required to pay our collection expenses, including 
court costs and reasonable attorney fees.  

CREDIT INFORMATION  
You authorize us to disclose information regarding your Account to credit bureaus and other 
creditors who inquire of us about your credit standing. You also authorize us to request and use a 
report(s) from outside credit reporting agencies in considering your original request for credit or 
in connection with renewal or continuation of the credit for which you have applied. If you 
request it, we will tell you whether or not we asked for such a report, and if we have, give you 
the name and address of the agency or agencies.  

EFFECT OF AGREEMENT  
This agreement will be effective when you or an authorized user uses the Card or the Account, or 
if you fail to cut your Card in half and return it to us within 30 days after it is issued to you. This 
agreement applies to all transactions on your Account even though the sales, cash advance, 
credit, or other slips you sign or receive may contain different terms.  

FEES 
If you fail to make any minimum payment within 35 days of the statement date, a late fee will be 
imposed as set forth in the fee schedule. 

Your Card is also subject to other applicable fees as set forth in the fee schedule.  

The fee schedule accompanies this Agreement and Disclosure and is incorporated by this 
reference. We will charge such fees against your Account.  

NO WAIVER  
We can delay enforcing any of our rights any number of times without losing them.  

STATEMENTS  
Statements and notices will be mailed to you at the most recent address given to us. Notice sent 
to any one of you will be considered notice to all. The monthly statement will identify the 
merchant, electronic terminal or financial institution at which transactions were made, but sales, 
cash advance, credit, or other slips cannot be returned with the statement. You should retain the 
copy of such slips furnished at the time of the transaction in order to verify the monthly 
statement. 

ACCOUNT BALANCE RESTRICTIONS  
In order to be approved for and maintain a Secured Visa Account, you agree to give us a specific 
pledge of shares which will equal your credit limit. You may cancel your Secured Visa Account 

 
 
 
 
 
 
 
 
 
at any time without penalty and redeem your pledged shares by paying any amounts borrowed 
through the use of your Card. In order to be certain that your entire balance and all advances on 
your Account are paid, any shares pledged may not be available for 30 days after you have 
cancelled your Account and any outstanding balance is paid in full.  

AUTOMATIC PAYMENT SERVICE  
If you requested to have your Card payment made automatically, your payment will be made 25 
days after the statement print date. If the payment date falls on a weekend or holiday, the 
payment will be made the next processing day. Payments will be based on the ending balance 
from the previous month’s statement.  

If you wish to cancel this service, you may notify us either by calling or writing, at any time, up 
to 3 business days before the scheduled date of the transfer. You must follow up any oral 
notification, in writing, within 14 days of the oral notification.  

ILLEGAL USE OF FINANCIAL SERVICES  
Any financial service provided by the credit union may be used for any transaction permitted by 
law. You agree that illegal use of any financial service will be deemed an action of default and/or 
breach of contract and such service and/or other related services may be terminated at our 
discretion. Illegal use includes, but is not in any way limited to, unlawful Internet gambling. You 
further agree, should illegal use occur, to waive the right to sue us for such illegal activity directly 
or indirectly related to it. You also agree to indemnify and hold the credit union harmless from any 
suits or other legal action or liability, directly or indirectly, including credit union expenses 
associated with defense of such law suits or other legal action, including attorney fees, resulting 
from such illegal use.  

BLOCKING CARDS AND/OR REFUSAL TO AUTHORIZE TRANSACTIONS 
We may block this Card due to the appearance of unusual spending behaviors or block transactions 
originating in certain domestic or international regions where there is a high volume of fraud.  

CONVENIENCE CHECKS  
If we offer the service, you may request convenience checks to access your Account. You can 
access your revolving line of credit to purchase goods and services or to obtain cash up to the 
amount of your credit limit through the use of convenience checks. Use of your convenience 
checks is a cash advance on your Account and is subject to a $10,000 daily limit. We are not 
required to honor a convenience checks that will cause you to exceed your credit limit. We will 
not pay a convenience check if at the time the check is presented, you are in default or we have 
suspended, terminated or cancelled your Account. Each convenience check must be in the form 
we have issued to you. Convenience checks may be used only by the person whose name is 
printed on the check. You are responsible for all authorized use of your convenience checks. You 
may not use a convenience check to pay any amount which you owe us under your Account. 
Your monthly statement will show you an itemization of the convenience checks posted to your 
Account during the billing cycle. Convenience checks paid by us will not be returned to you with 
your monthly statement. You may order a stop payment on a convenience check by notifying us 
orally or in writing. Oral notices must be confirmed in writing within fourteen (14) days. Written 
stop payment orders will remain in effect for six (6) months, but may be renewed for an 

 
 
 
 
 
additional six (6) month period by written notice during the time the stop payment order was 
effective. We will charge a fee when we place a stop payment on your check(s). Convenience 
checks are the property of the credit union. We reserve the right to revoke them at any time. You 
agree to return them at our request.  

INTEGRATED DOCUMENTS  
Any separate sheet of paper, which is delivered to you with this Agreement, is an integrated part 
of this Agreement and Disclosure.  

HOLDER IN DUE COURSE NOTICE (If applicable) 

NOTICE: any holder of this consumer credit contract is subject to all claims and defenses which 
the debtor could assert against the seller of goods or services obtained pursuant hereto or with the 
proceeds hereof. Recovery hereunder by the debtor shall not exceed amounts paid by the debtor 
hereunder. 

YOUR BILLING RIGHTS - KEEP THIS DOCUMENT FOR FUTURE USE  
This notice tells you about your rights and our responsibilities under the Fair Credit Billing Act. 

What To Do If You Find A Mistake On Your Statement: 

If you think there is an error on your statement, write to us at: 

Hudson Valley Federal Credit Union       
159 Barnegat Rd. 
Poughkeepsie, NY 12601 

You may also contact us on the web at hvfcu.org and click on “Contact Us.”  

In your letter, give us the following information: 

Account information: Your name and account number. 
Dollar amount: The dollar amount of the suspected error. 
Description of problem: If you think there is an error on your bill, describe what you believe is 
wrong and why you believe it is a mistake. 

You must contact us: 

Within 60 days after the error appeared on your statement. 

At least 3 business days before an automated payment is scheduled, if you want to stop payment 

on the amount you think is wrong.  

You must notify us of any potential errors in writing or electronically. You may call us, but if 
you do we are not required to investigate any potential errors and you may have to pay the 
amount in question. 

 
 
 
 
  
  
  
  
 
  
  
  
 
  
What Will Happen After We Receive Your Letter:  

When we receive your letter, we must do two things: 
1. Within 30 days of receiving your letter, we must tell you that we received your letter. We will 
also tell you if we have already corrected the error. 

2. Within 90 days of receiving your letter, we must either correct the error or explain to you why 
we believe the bill is correct. 

 While we investigate whether or not there has been an error: 
We cannot try to collect the amount in question, or report you as delinquent on that amount. 
The charge in question may remain on your statement, and we may continue to charge you 

interest on that amount. 

While you do not have to pay the amount in question, you are responsible for the remainder of 

your balance. 

We can apply any unpaid amount against your credit limit. 

After we finish our investigation, one of two things will happen: 
If we made a mistake: You will not have to pay the amount in question or any interest or other 

fees related to that amount. 

If we do not believe there was a mistake: You will have to pay the amount in question, along 
with applicable interest and fees. We will send you a statement of the amount you owe and the 
date payment is due. We may then report you as delinquent if you do not pay the amount we 
think you owe. 

If you receive our explanation but still believe your bill is wrong, you must write to us within 10 
days telling us that you still refuse to pay. If you do so, we cannot report you as delinquent 
without also reporting that you are questioning your bill. We must tell you the name of anyone to 
whom we reported you as delinquent, and we must let those organizations know when the matter 
has been settled between us. 

If we do not follow all of the rules above, you do not have to pay the first $50 of the amount you 
question even if your bill is correct. 

YOUR RIGHTS IF YOU ARE DISSATISFIED WITH YOUR CREDIT CARD PURCHASES: 
If you are dissatisfied with the goods or services that you have purchased with your 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 purchase. 

To use this right, all of the following must be true: 

1. The purchase must have been made in your home state or within 100 miles of your current 
mailing address, and the purchase price must have been more than $50. (Note: Neither of these 
are necessary if your purchase was based on an advertisement we mailed to you, or if we own the 
company that sold you the goods or services.) 

 
 
 
 
 
 
 
 
2. You must have used your Card for the purchase. Purchases made with cash advances from an 
ATM or with a check that accesses your Card Account do not qualify. 

3. You must not yet have fully paid for the purchase. 

If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in 
writing at: 

Hudson Valley Federal Credit Union       
159 Barnegat Rd. 
Poughkeepsie, NY 12601 

or electronically at hvfcu.org and click on “Contact Us”. 

While we investigate, the same rules apply to the disputed amount as discussed above. After we 
finish our investigation, we will tell you our decision. At that point, if we think you owe an 
amount and you do not pay, we may report you as delinquent. 

Disclosure Information for Visa Platinum and Visa Platinum Rewards 

Visa® Platinum 

Credit Card Account Opening Disclosure 
Interest Rates 
and Interest 
Charges 
Annual 
Percentage Rate 
(APR) for 
Purchases 

11.25% to 17.25% This APR will 
vary with the market based on the 
Prime Rate 

Visa Platinum Rewards 

12.25% to 18.00% This APR will 
vary with the market based on the 
Prime Rate 

APR for Balance 
Transfers 

APR for Cash 
Advances 

11.25% to 17.25% 
This APR will vary with the market 
based on the Prime Rate 
11.25% to 17.25% 
This APR will vary with the market 
based on the Prime Rate 

12.25% to 18.00%  
This APR will vary with the market 
based on the Prime Rate 
12.25% to 18.00% 
This APR will vary with the market 
based on the Prime Rate 

Penalty APR and 
When it Applies 

None 

Paying Interest 

Your due date is at least 25 days after 
the close of each billing cycle. We 
will not charge you any interest on 
purchases if you pay your entire 
balance by the due date each month. 
We will begin charging interest on 
cash advances and balance transfers 
on the transaction date. 

For Credit Card  To learn more about factors to 

None 

Your due date is at least 25 days after 
the close of each billing cycle. We 
will not charge you any interest on 
purchases if you pay your entire 
balance by the due date each month. 
We will begin charging interest on 
cash advances and balance transfers 
on the transaction date. 
To learn more about factors to 

 
 
 
  
 
 
 
Interest Rates 
and Interest 
Charges 
Tips from the 
Consumer 
Financial 
Protection 
Bureau 
Fees 
Transaction Fees   
Cash Advance 
Foreign 
Transaction 
Penalty Fees 
Late Payment 

Visa® Platinum 

consider when applying for or using a 
credit card, visit the website of the 
Consumer Financial Protection 
Bureau. 

2% of advance amount 
Exchange Rate plus 1% of 
transaction 

up to $29 

Visa Platinum Rewards 

consider when applying for or using a 
credit card, visit the website of the 
Consumer Financial Protection 
Bureau. 

2% of advance amount 
Exchange Rate plus 1% of 
transaction 

up to $29 

How We Will Calculate Your Balance: We use a method called “average daily balance” 
(including purchases, cash advances and balance transfers). See the Variable Rate Credit Card 
Agreement and Truth in Lending Disclosure for more details. 

Billing Rights: Information on your rights to dispute transactions and how to exercise those 
rights are provided in the Variable Rate Credit Card Agreement and Truth in Lending 
Disclosure. 

Your new credit card has a variable rate. Additional rate information is as follows: 

MONTHLY PERIODIC RATE FOR APR SHOWN 
ABOVE FOR PURCHASES, CASH ADVANCES, AND 
BALANCE TRANSFERS 
MARGIN 

Visa Platinum 

Visa Platinum 
Rewards 

0.9375% TO 
1.4375% 

1.0208% TO 
1.5000% 

8.00% TO 14.00%  9.00% TO 15.00% 

The Annual Percentage rate and monthly periodic rate above is in effect until the next monthly 
change. Refer to your Variable Rate Credit card Agreement and Truth in Lending Disclosure for 
more information regarding your variable rate.