Barnett Banks of Florida, Inc. and Subsidiaries - Page 9

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          cardholders were added, which petitioner offered through the use            
          of third-party providers.  Petitioner provided loss-protection              
          service whereby cardholders who lost their wallets or purses                
          could notify the designated third-party provider, with whom they            
          had listed all of their credit card accounts, and this company              
          would contact all the card issuers.  Petitioner made available              
          life insurance in conjunction with the use of the card to                   
          purchase an airline ticket.  Similarly, rental car insurance was            
          provided when the cardholder charged the rental to the card.                
               The amount of the annual fee to be charged was limited by              
          competitive factors in the industry.  The annual fee did not                
          cover the entire cost of serving the cardholders.  During 1980              
          and 1981, petitioner's revenue with respect to the credit card              
          program derived from four sources:  (1) Merchant discounts, (2)             
          interchange fees, (3) interest charges paid by cardholders with             
          outstanding (revolving) balances, and (4) the annual fees paid by           
          cardholders.  In 1979, the year prior to the institution of the             
          annual fee, 66 percent of petitioner's Visa revenue came from               
          interest charges, 33 percent from merchant discounts and                    
          interchange fees, and the remaining 1 percent from other sources.           
          The issuing banks have never placed any restrictions on their use           
          of the annual fees for any corporate purpose.                               
          Usual Banking Practices                                                     
               Under ordinary commercial banking practices, borrowers of              
          money are charged interest based on the amount of money borrowed.           




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