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SettleADebt R088 PASS-01

Appendix M1 to 12 CFR Part 1026 — Repayment Disclosures

Appendix M1 supplies methods for specified repayment disclosures. It does not set a universal contractual minimum payment, supply an actual payoff quote, or establish affordability. Its calculations use account-specific inputs together with expressly permitted assumptions, alternative methods, rounding rules, and accuracy tolerances. The associated disclosure obligation and its exceptions appear in § 1026.7(b)(12). Consumer Financial Protection Bureau+3

The complete current CFPB-displayed Appendix M1 was read, including paragraphs (a)–(f), every nested assumption, and its illustrations. The linked Appendix M2 was also read completely because M1 expressly refers to its sample calculations. M2 is a published illustration written in SAS; it has not been executed, converted into a calculator, or treated as a general-purpose algorithm. Consumer Financial Protection Bureau+3

A material source-status qualification arose in the account-definition cross-reference. The eCFR display of § 1026.2(a)(15) included wording adopted by the 2024 overdraft rule, while the CFPB display showed different wording. The adopted 2024 clause was traced, and Public Law 119-10 expressly states that the identified rule has no force or effect. That enacted limitation is preserved below; the eCFR currency banner is not treated as sufficient proof that the displayed overdraft amendment is operative. ecfr.gov+4

Actual access date: October 28, 2026, America/Los_Angeles, beginning at 00:12 PDT. All readings reported here occurred during this investigation. Earlier reports supplied no substantive premise or source evidence.

Reference convention: “S001,” “C001,” “M001,” and “B01” below refer to the corresponding R088-P1 source, claim, measurement, and branch entries. References to an unexamined provision are expressly identified as pointers, not verified findings about that provision.

1. Source register

These are public statutes, regulations, official interpretations, and adopted rulemaking publications. Multiple displays of the same provision are grouped; they are not independent corroboration.

For HTML, a PDF page index is not applicable. For PDFs, printed pagination and zero-based PDF indices are distinguished. Screenshot requests did not provide reviewable image content in the returned material; one timed out. Accordingly, the PDF readings below are parsed-text readings, not assertions of pixel inspection.

2. Actual organization and scope of the calculation framework

M1 has six lettered divisions. The five calculation outputs are a minimum-payment repayment duration, minimum-payment total cost, thirty-six-month monthly payment, thirty-six-month total cost, and the savings comparison between the two costs. Definitions precede them. M1 contains prose instructions and illustrations; the linked M2 supplies an algebraic/code illustration. Consumer Financial Protection Bureau+3

The underlying duty is conditional. Section 1026.7(b)(12) addresses a credit card account under an open-end, not home-secured consumer credit plan, subject to its own exceptions and the periodic-statement framework. The definitions distinguish consumer purpose, credit access, open-end characteristics, and excluded account categories. They do not make every loan, transfer, consolidation, or debt-relief arrangement subject to M1. Consumer Financial Protection Bureau+4

3. Atomic claim register

3A. Source status, authority, definitions, and disclosure applicability

3B. Complete M1 calculation instructions

3C. Linked sample, official interpretations, and ancillary information duties

3D. Adoption history and remaining legal/method limits

4. Source-to-method specification and plain-text formulas

4.1 Definitions used in the transcriptions

The following symbols describe the published instructions. They are not populated account fields.

F01 — Minimum-payment duration and total cost

M1 requires applicable formulas; it does not print a single universal minimum-payment recurrence. For multiple applicable formulas, its longest-period rule can be transcribed as follows. C035, C040–C055 apply.

Plain text

For each applicable minimum-payment formula j:
    T_j = repayment duration calculated for the balance portion
          to which formula j applies, using M1's required inputs
          and the selected permitted assumptions/account terms.

T_account = max(T_1, T_2, ..., T_k)
Units: months before the required duration-display conversion.

C_min = sum(Principal[t] + Interest[t], over the calculated
            minimum-payment repayment period)
Units: USD.

This is not:
    a universal minimum-payment formula;
    a contractual payoff quote; or
    permission to invent a finite T_account when no amortization occurs.

For negative or no amortization, the separate § 7(b)(12)(ii) disclosure route applies. The absence of a finite minimum-payment result does not authorize an invented payoff duration. C029.

F02 — M2’s periodic-rate, weighting, and equal-payment illustration

The next formulas reproduce the linked source example’s method, with its inputs left unpopulated. They are not a new financial example. M1 permits other methods meeting C060.

Plain text

M2 month-length convention:
    days = 365 / 12
Units: assumed days per calculation month.

For i = 1, 2, 3:
    xperrate[i] = (apr[i] / 365) * days
Units: decimal rate per assumed calculation month.

If expm > 0:
    xperrate1a =
        (expm / 36) * xperrate[1]
        + (1 - expm / 36) * (rrate / 365) * days
Otherwise:
    xperrate1a = xperrate[1]

tbal = cbal[1] + cbal[2] + cbal[3]
Units: USD.

perrate36 =
    (cbal[1] * xperrate1a
     + cbal[2] * xperrate[2]
     + cbal[3] * xperrate[3]) / tbal
Units: decimal rate per assumed calculation month.

N = 36
Units: number of monthly payments.

pvaf = (1 - (1 + perrate36) ** (-N)) / perrate36

pmt01 = round(tbal / pvaf, 0.01 USD)
Units: USD per monthly payment.

sumpmts36 = pmt01 * 36
Units: USD.

** means exponentiation. The displayed divisions require valid denominators. The source code does not print a zero-total-balance or zero-periodic-rate branch for these expressions. No limiting formula or software fallback is invented here. M1(d)(2)’s prose governs the fraction of the comparison period for which each promotional/successor rate applies; the sample’s expm marker is not a general contractual date-counting instruction. C057–C070, C076.

F03 — M2’s minimum-payment loop, as written

This is a non-executed reference transcription, not deployable code. The source’s separate conditions and assignments are deliberately preserved.

Plain text

Initialization:
    month = 0
    sumpmts = 0 USD
    perrate[i] = (apr[i] / 365) * days, for i = 1, 2, 3

Each iteration:
    month = month + 1

    pmt = round(pmin * tbal, 0.01 USD)

    If month >= expm AND expm != 0:
        perrate[1] = (rrate / 365) * days

    If pmt < dmin:
        pmt = dmin

    For i = 1, 2, 3:
        xxxbal[i] = round(cbal[i] * (1 + perrate[i]), 0.01 USD)

    fc = xxxbal[1] + xxxbal[2] + xxxbal[3] - tbal
    Units of fc: USD for this calculation month.

Final-payment branch printed in M2:
    If pmt > (tbal + fc):
        For i = 1, 2, 3, in that order:
            If cbal[i] > 0:
                pmt = round(cbal[i] * (1 + perrate[i]), 0.01 USD)

Allocation block 1:
    If pmt <= xxxbal[1]:
        cbal[1] = xxxbal[1] - pmt
        cbal[2] = xxxbal[2]
        cbal[3] = xxxbal[3]

Allocation block 2:
    If pmt > xxxbal[1]
       AND xxxbal[2] > 0
       AND pmt <= (xxxbal[1] + xxxbal[2]):
        cbal[2] = xxxbal[2] - (pmt - xxxbal[1])
        cbal[1] = 0
        cbal[3] = xxxbal[3]

Allocation block 3:
    If pmt > xxxbal[2] AND xxxbal[3] > 0:
        cbal[3] = xxxbal[3] - (pmt - xxxbal[1] - xxxbal[2])
        cbal[2] = 0

The three blocks are separate source conditions, not an "else-if" rewrite.
A component not assigned by a block retains its existing value.

End of iteration:
    sumpmts = sumpmts + pmt
    tbal = cbal[1] + cbal[2] + cbal[3]

Continuation:
    If tbal > 0:
        repeat the iteration.
    Otherwise:
        leave the loop.

Sample savings expression:
    savtot = round(sumpmts, 1 USD) - round(sumpmts36, 1 USD)

Three limits matter:

1. The final-payment branch is not written as a general total-balance cap; it assigns from positive component balances in source order.
2. The promotional comment and month >= expm test are preserved without silently rewriting the boundary.
3. The sample’s continuation test does not contain a separate general non-amortization detector. The regulation supplies the relevant replacement-disclosure rule; an implementation cannot be declared complete merely because it reproduces this loop.

These are observations about the text read, not findings that a particular calculator or creditor is inaccurate. C071–C076. ecfr.gov+3

F04 — Cost comparison and savings sequence

Plain text

C_36 = sum(Principal_36[t] + Interest_36[t], t = 1 through 36)
Units: USD.

In M2's equal-payment illustration:
    C_36 = 36 * P_36

Choose the permitted common monetary display increment:
    q = 1 USD
or:
    q = 0.01 USD

Displayed minimum-payment cost = round(C_min, q)
Displayed 36-month cost       = round(C_36, q)

Savings =
    round(C_min, q) - round(C_36, q)
Units: USD.

The stated sequence rounds the two cost components before subtraction. The costs and savings inherit their specified calculation/accuracy dependencies. No provider fee, tax consequence, disputed balance, settlement acceptance, or other external outcome is supplied by this equation. C055, C063–C065.

F05 — Duration display and the two duration-accuracy routes

Plain text

Duration display:
    If the repayment duration is less than 2 years:
        disclose the estimate in months.
    Otherwise:
        disclose years rounded to the nearest whole year.

The 2010 adoption explanation:
    fractional year < 0.5  -> round down;
    fractional year >= 0.5 -> round up.

Duration-accuracy route 1, before years-display rounding:
    T_ref - 2 months <= T_issuer <= T_ref + 2 months

Duration-accuracy route 2:
    Where the years-display rule applies,
    disclose the correct rounded number of years under that rule,
    even if the underlying estimate differs by more than 2 months.

The benchmark must preserve any account terms chosen instead
of the listed M1(b)(4) assumptions.

This does not establish how every fractional-month or monetary-tie case must be implemented. C030, C052–C055.

F06 — Thirty-six-month payment tolerance

For a positive benchmark payment, the source’s percentage rule can be expressed without calculating an actual result:

Plain text

P_ref = proper 36-month monthly payment estimate
        after the specified disclosure rounding.
P_issuer = corresponding issuer estimate after that rounding.
Units: USD per monthly payment.

P_ref - (0.10 * P_ref) <= P_issuer <= P_ref + (0.10 * P_ref)

Equivalent percentage comparison, only when P_ref > 0:
    abs(P_issuer - P_ref) / P_ref <= 0.10

The denominator is the properly determined, rounded benchmark payment. A zero-denominator implementation rule, a general negative-input rule, and proof of an actual tool’s accuracy remain absent. C062, C076.

5. Provision-specific comparison

6. Complete measurement register

This register covers quantities relied on in this report. Statutory section numbers, source IDs, printed-page numbers, and PDF indices are locators recorded in the source register, not financial inputs. Incidental quantities in surrounding material outside the reliance bounds are not adopted.

6A. Operative calculation and disclosure quantities

6B. Source illustrations and sample-code quantities

These are published source illustrations only. They are not newly constructed account examples and have not been recomputed into a payoff result.

6C. Version, publication and application measurements

7. Conditional branches and branch-level coverage

Status terminology: “Answered boundary” means the generic instruction and its limit are established within the read sources. “Partial” identifies a remaining authority or method gap. Every actual application remains absent and excluded.

8. Wholly blank analytical worksheet

The following is an empty analytical structure. It is not an intake form, account-data request, calculator, or decision instrument. All authority, evidence, analysis, and result cells are intentionally blank.

9. Granular question-to-claim coverage

Branch-specific coverage, missing predicates, and next inquiries are supplied individually in B01–B42 above. This table provides the numbered-request and material-subquestion crosswalk.

10. Source-read and failure log

10A. Successful and bounded readings

10B. Exact failures and visual-access limits

No failed retrieval is treated as repeal, withdrawal, legal absence, a quota event, or a reason to bypass an access control.

11. Explicit unresolved gaps

12. Researcher self-check — not independent review

END R088 PASS-01.