Signet Banking Corporation - Page 5

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          life insurance.  Petitioner also received a fee of 2 percent of             
          the transaction amount for automated teller machine (ATM) and               
          check access until May 1983.                                                
          3.   Annual Membership Fees                                                 
               a.   Petitioner’s Decision to Charge an Annual Membership              
                    Fee                                                               
               In 1980, petitioner's MasterCard business lost money because           
          the cost of funds used by petitioner was high compared to the               
          finance charge it could apply to MasterCard cardholders.                    
               Petitioner had three types of cardholders.  About 70 percent           
          were in the "revolver" group (i.e., those who paid less than the            
          balance due each month and incurred finance charges on the                  
          outstanding balance).  About 30 percent were "convenience users"            
          (i.e., those who used their cards, paid their balance in full,              
          and thus did not owe finance charges).  A small number were                 
          "inactive" (i.e., those who may have used their MasterCards as              
          identification but did not use them to pay for goods or                     
          services).  Convenience users generated interchange fees but not            
          finance charges.  As a group they were minimally profitable.                
          The inactive group cost petitioner money but generated no income.           
          Petitioner decided to impose an annual membership fee to recover            
          some of the cost of delivering services to each group.                      
               Petitioner began to charge its MasterCard cardholders an               
          annual membership fee in April 1981.  Thereafter, petitioner's              
          credit card division derived income from commissions deducted               




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