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

Express Credit Card Current Credit Card Agreements

The filed agreement discloses a purchase APR of 35.99%. Below: every term the document states, what it leaves out, and how the cost compares with the rest of the database.

Disclosed rates and fees

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

Terms as disclosed in the filed agreement for Express Credit Card Current Credit Card Agreements
Purchase APR35.99%
Penalty APR39.99%
Annual fee$35.88
Late payment feeup to $41
Minimum interest charge$3

Analysis

Express Credit Card Current Credit Card Agreements, as filed by Comenity Bank, carries a 35.99% purchase APR, a $35.88 annual fee and a 39.99% penalty rate. That purchase rate ranks near the 97th percentile across this corpus of 4,587 filings.

What this filing discloses

Comenity Bank submitted the terms for Express Credit Card Current Credit Card Agreements to the CFPB's agreement database; this is what they contain. The filing runs 20 pages.

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

How the purchase rate compares

Set beside the rest of the index, the purchase APR of 35.99% lands at the 97th percentile; it ranks among the most expensive figures in the whole collection.

What the rate means in dollars

At the disclosed purchase APR, $1,000 revolving for a full year costs something like $433 in interest.

A card priced at the corpus median of 21.99% would charge roughly $246 on that balance. This one charges about $187 more per year.

Note the $3 minimum interest charge, which overrides the arithmetic above whenever the calculated interest falls below it.

These figures are arithmetic on the disclosed rate, not a quote: they assume the balance is never reduced, ignore any payments, and take no account of fees charged separately.

Fees, and what triggers them

Holding the card costs $35.88 a year before any transaction takes place — about the 84th percentile among agreements in this index that state a fee.

The no-interest path

Where interest applies at all, the filing bills at least $3. On a tiny balance that floor can dwarf the rate itself.

When a payment is late

The agreement discloses penalty pricing of 39.99% — about the 86th percentile of the 794 penalty rates recorded across this index.

Measured in money, moving from 35.99% to 39.99% costs an extra $175 or so annually on $3,000 — a far larger number than any single late fee.

The maximum late fee is $41 — roughly the 89th percentile of the late fee ceilings disclosed across this index.

Against the rest of Comenity Bank's filings

There are 45 filings from Comenity Bank in this index. Their disclosed purchase rates run from 30.24% to 35.99%, and this one at 35.99% is more expensive than 7 of them.

The limits of this document

Absent from the captured terms: anything about cash advances, balance transfer terms, a foreign transaction fee and a grace period. The original document is the place to look for any of these.

What this analysis can address is bounded by the filing: rates, fees and the terms around them. Everything a card issuer might advertise — rewards, benefits, bonuses, who qualifies — falls outside the document and outside this review.

The document itself

Everything here is a reading of the filed agreement, 20 pages of it, which is linked above and which governs. Terms also change between filings, so the date on the document matters.

In short

35.99% on purchases is the number that dominates this agreement. Paid in full each cycle it never applies; carried, it is among the dearer prices in this index. Note that the $35.88 annual fee falls due whether the card is used or not.

The source document

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

Open the filed agreement (PDF)

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Other cards from Comenity Bank

All 45 agreements from Comenity Bank