Pricing Information for the Commerce Miles Credit Card

The Pricing Information for the Commerce Miles Credit Card filing quotes margins over Prime instead of finished rates. What that leaves knowable — and what it does not — is the subject of this analysis.

What the document actually states

This page covers the agreement Commerce Bank filed for Pricing Information for the Commerce Miles Credit Card. The filing runs one page.

The filing is explicit about a penalty rate, a late payment maximum, a foreign transaction fee and a grace period. A purchase rate, a cash advance rate and a balance transfer rate are not stated.

The disclosure table in this document parsed only moderately cleanly; the numbers are reported as read, with that caveat attached.

A margin over Prime, not a rate

What this agreement discloses is a set of margins added to the Prime Rate. Until Prime is supplied, none of these figures is an APR, and this page will not treat them as one.

As read from the document: 23.99 points for penalty pricing.

The practical consequence is that this card has no single disclosed price. The cost of carrying a balance moves whenever the Prime Rate moves, in lockstep and without notice, and no arithmetic on this page can tell you what it costs today.

Confidence in the parse of this filing is moderate rather than high, so the figures below are best checked against the original.

The downside terms

The maximum late fee is $40 — roughly the 72nd percentile of the late fee ceilings disclosed across this index.

Charges beyond interest

Cash advances carry a cash advance fee of $10 or 5% of the advance, whichever is greater.

Transfers are charged $10 or 5% of the amount transferred, whichever is greater, though no distinct transfer APR appears in the document. Transferring $7,500 would cost roughly $375 at the door.

No foreign transaction fee is charged, which puts this filing in the roughly 22% of disclosing agreements here that do not take a cut of overseas spending.

Grace period and minimum charge

Anyone clearing the statement balance inside 25 days pays no purchase interest at all under this filing. That matches the 25-day median across the corpus almost exactly.

Where interest applies at all, the filing bills at least $2.50. On a tiny balance that floor can dwarf the rate itself.

The issuer's other agreements

165 separate Commerce Bank filings appear in the corpus.

What is outside the disclosure

Absent from the captured terms: a purchase rate and an annual fee. The original document is the place to look for any of these.

More broadly, a CFPB agreement filing is a legal and pricing document. It does not describe rewards, benefits, sign-up offers, eligibility or approval criteria, and nothing of that kind has been inferred on this page. Where a card has features of that sort, they live outside this document entirely.

Where the authority sits

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

In short

The honest summary is that this filing discloses a structure rather than a price. The margins are real and comparable to each other; the cost of borrowing is whatever Prime makes it.