[kpeng]

The disclosure still applies to credit card splits. The disclosures are required for financial products, regardless of repayment method. ACH Remits are not "fixed", or at least they should not be. ACH remit amounts should be calculated based on a percentage of merchant's calculated average sales at the time of funding. Should merchant's sales deviate, the ACH remit amount should as well. This is why "true-ups" are done on a regular basis.