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SUbstantial injury usually entails monetary harm. 20 trivial or merely abstract harms e. G. , the poignant impact of an act or convention are generally insufficient for a finding of large injury. HOwever an act or custom that causes or is likely to cause even a small amount of monetary harm to one person may meet the huge injury normal if the act or habit results in or is likely to result in harm to a large number of people. A review of the facts presented in credit card lending consultation 1 demonstrates how a financial harm, in the collect, was found massive by coaches even if the harm, on a case by case basis, was small. HEre, the bank assigned credit card payments i. E. , the necessary minimum payment on books with many rate tiers in such a way as to credit the equations with lower annual interest rates aprs first. SPecifically, for all reports with multiple rate tiers i. E. , separated aprs for gains, cash progresses, balance bears, message rates, etc. , the bank applied the betrayer’s monthly payment solely to the lowest rate tier, perhaps following in the capitalization of pursuit to the balance with the highest rate. FOr example, where a customer has both a acquirement balance and a balance worker balance, the lower aprs are generally appointive to balance carries and the highest appointed to acquisition equations. AS a result, any compensations made by the buyer would first be applied entirely to the balance deliver balance. UNless the payment entirely pays off the balance give balance, the sideline accrued on the achievement balance is capitalized, and the balance adds. INjury caused to a group of consumers by a bank’s exercises, in its totality, may be judged huge by the fdic; injury of a similar nature limited to only one consumer may not. THerefore, banks should routinely examine their business labors to ensure such exerts do not or are not likely to substantially injure buyer, either individually or in the assemble. IN credit card lending interview 1, the bank allocated credit card costs on scores with manifold rate tiers first to equations with lower aprs, potentially consequent in the capitalization of unpaid interest to addition with higher aprs. WHile the harm or likely harm to one cardholder caused by this practice arguably may not have been big, when multiplied by all cardholders with rate tiered ac counts, such harm or its likelihood was considered to be huge. AS a result of this convention, the client’s check bounced, causing a variety of harms to the buyer. FOr chest, when the check was denied because it would have caused the client’s credit limit to be exceeded, the purchaser still owed the debt that the check was first written to cover. IN increase, the client may be liable for fees consequent from the check not being honored. FOr example, the payee may pass on the cost of the bounced check to the shopper and, subject to on what the check was for, may assess a late fee against the grazer if the check was used to pay a bill that then became past due. ONce the check is written, if there is a diminish in the credit line such that the bank will not cover the check, the harm to the bank’s purchaser is unavoidable. ALthough the advisors found this tradition to be injurious to buyers i. E. , longer amortization periods and, thus, higher costs for the higher rate equations; see credit card audience 1, and the harm not fairly avoidable, the consultants rated the injury was, in this casing, outweighed by the benefits in the form of low message rates for balance transfers and similar hortative rates e. G. , beginning low rates for new scores. DEtermining whether this element of the unfairness test is met i.