OpenChainGraph Suite · ART-233 · Fair Lending & Adverse Action 伦

CARD Act Ability to Pay

Checks credit-card underwriting against the CARD Act ability-to-pay rules per Reg Z §1026.51: income and asset sufficiency test, under-21 cosigner or independent income requirement, and §1026.52(b) penalty-fee safe harbors ($32 first violation, $43 subsequent). The CFPB late-fee $8 rule was vacated by consent judgment on April 15, 2025 (U.S. District Court, N.D. Tex., Chamber of Commerce v. CFPB, No. 4:24-cv-00213-P) — $32/$43 thresholds remain in force.

Reg Z §1026.51 Reg Z §1026.52(b) CARD Act 2009 Under-21 Rule $32/$43 Safe Harbor $8 Rule Vacated 2025-04-15
🔒 All inputs are processed locally in your browser. No data is transmitted. Do not enter real personal data — use synthetic or anonymised inputs only.
ⓘ Not legal or compliance advice. The CFPB $8 late-fee rule (88 FR 18906) was vacated by consent judgment on April 15, 2025 (U.S. District Court, N.D. Tex., Chamber of Commerce v. CFPB, No. 4:24-cv-00213-P). The $32/$43 penalty-fee safe harbors under §1026.52(b) remain current law. Verify applicant age and income independently before underwriting decisions.
Applicant Profile
Under-21 triggers cosigner or independent income requirement (§1026.51(b)).
Independently verifiable income. For applicants under 21, must be their own income.
Liquid assets available to service the credit line.
All recurring monthly debt payments (auto, student, etc.) excluding housing.
Under-21 / Cosigner
Satisfies the under-21 independent-means exception (§1026.51(b)(1)(ii)).
Monthly minimum payment as % of balance (typically 1–2%). Used for ATP ratio check.
Penalty-Fee Tier (§1026.52(b) Safe Harbor)
First violation: $32 safe harbor. Subsequent (within 6 billing cycles): $43 safe harbor. CFPB $8 rule vacated 2025-04-15 (consent judgment, N.D. Tex.) — $32/$43 remains.
Ability to Pay Decision
Under-21 Gate
Penalty-Fee Safe Harbor
Execution Hash (SHA-256)







  

    
Ask your agent

    
  

  
Copy this paragraph into Claude, OpenClaw, or any MCP-aware agent to run this exact tool, with this sample, and verify the artifact.

  
Run the AINumbers MCP tool `check_card_act_ability_to_pay`. Task: Evaluate a credit card application against CARD Act §1026.51 ability-to-pay requirements.
Call it with arguments: {"policy_parameters":{"applicant_age":19,"annual_income":0,"total_assets":0,"requested_credit_limit":1000,"has_cosigner":false,"method":"income_assets"}}
Verify before trusting: call `verify_execution_hash` on mcp.ainumbers.co (https://mcp.ainumbers.co/mcp) with the parameter `claimed_hash` set to the returned `execution_hash`, passing the full artifact the run returned (the object containing `policy_parameters` + `output_payload` + `execution_hash`; equivalently `policy_parameters` + `output_payload` with `claimed_hash`), not the bare hash string.
Return the ledger link https://ledger.ainumbers.co/ so a human can re-verify without contacting us.
PII rule: All inputs are processed locally in your browser. No data is transmitted. Do not enter real personal data — use synthetic or anonymised inputs only.
Open the tool with the sample prefilled: https://ainumbers.co/chaingraph/art-233-check-card-act-ability-to-pay.html#p=v1.H4sIAAAAAAAA_wGDAHz_eyJhcHBsaWNhbnRfYWdlIjoxOSwiYW5udWFsX2luY29tZSI6MCwidG90YWxfYXNzZXRzIjowLCJyZXF1ZXN0ZWRfY3JlZGl0X2xpbWl0IjoxMDAwLCJoYXNfY29zaWduZXIiOmZhbHNlLCJtZXRob2QiOiJpbmNvbWVfYXNzZXRzIn1oUGCqgwAAAA