Quote Originally Posted by J.Celifarco View Post
the max term was 36 months not 18. I understand that the max you saw was 18 months but they 100% went out 36 months I have spoken to merchants who have the program and have spoken to number of ISO's who have referenced this program
Quote Originally Posted by CreditGuy
(Both advertise 36 month terms but those terms are really more marketing than reality.)
In order to advertise a 36 month term on their public site (both CAN and ODC do) and not be in violation of UDAP, they need to offer the terms as part of normal course of business. That is, even if only 0.25% of all applicants (25 out of 10,000/month) would qualify it meets the test. For the purposes of using max term to proxy average term removing such a significant outlier is warranted.