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SUbstantial injury usually complicates financial harm. 20 trivial or merely speculative harms e. G. , the affecting impact of an act or tradition are normally insufficient for a finding of huge injury. HOwever an act or routine that causes or is likely to cause even a small amount of economic harm to one person may meet the big injury ordinary if the act or tradition results in or is likely to result in harm to a large number of people. A review of the facts granted in credit card lending meeting 1 manifests how a monetary harm, in the collect, was found huge by consultants even if the harm, on a case by case basis, was small. HEre, the bank apportioned credit card fees i. E. , the mandatory minimum payment on accounts with multiple rate tiers in such a way as to credit the addition with lower annual rate rates aprs first. SPecifically, for all reports with multifarious rate tiers i. E. , the requisite minimum payment on scores with many rate tiers in such a way as to credit the approximation with lower annual part rates aprs first. SPecifically, for all scores with many rate tiers i. E. , separated aprs for gains, cash proceeds, balance carries, message rates, etc. , the bank applied the client’s monthly payment solely to the lowest rate tier, possibly resultant in the capitalization of regard to the balance with the highest rate. FOr example, where a client has both a purchase balance and a balance transfer balance, the lower aprs are normally nominated to balance bears and the highest nominated to gain differentiation. AS a result, any payments made by the client would first be applied solely to the balance turn balance. UNless the payment entirely pays off the balance turn balance, the care accrued on the acquisition balance is capitalized, and the balance sums. INjury caused to a group of patrons by a bank’s exerts, in its totality, may be judged large by the fdic; injury of a similar nature limited to only one patron may not. THerefore, banks should routinely examine their concerns exerts to ensure such employs do not or are not likely to at bottom injure patrons, either apart or in the accumulate. IN credit card lending meeting 1, the bank distributed credit card remunerations on counts with many rate tiers first to approximation with lower aprs, potentially following in the capitalization of unpaid worry to differentiation with higher aprs. WHile the harm or likely harm to one cardholder caused by this tradition arguably may not have been massive, when multiplied by all cardholders with rate tiered ac counts, such harm or its odds was assessed to be substantial. AS a result of this practice, the patron’s check bounced, causing a variety of harms to the consumer. FOr chest, when the check was refused because it would have caused the consumer’s credit limit to be exceeded, the patron still owed the debt that the check was first written to cover. IN adding, the consumer 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 client and, depending on what the check was for, may assess a late fee against the dependent if the check was used to pay a bill that then became past due. ONce the check is written, if there is a decline in the credit line such that the bank will not cover the check, the harm to the bank’s customer is unavoidable. ALthough the counsellors found this practice to be harmful to buyers i. E. , longer amortization periods and, thus, higher costs for the higher rate division; see credit card audience 1, and the harm not moderately avoidable, the cabinet evaluated the injury was, in this instance, outweighed by the edges in the form of low message rates for balance abides and similar hortative rates e. G. , introductory low rates for new books. DEtermining whether this element of the unfairness test is met i. E. , whether an injury is outweighed by countervailing gains turns on the facts of each case; though the consultants in credit card lending conference 3 found the injury outweighed by the edges, a extra finding may result from other facts.