The New Brunswick Cost of Credit Disclosure Act and Regulation are scheduled to come into force on September 15, 2010. The new legislation will require that where a borrower must decline a rebate (or a portion of the rebate) in order to enter into a credit agreement at a particular interest rate, the APR must be calculated by factoring in the forgone non-stackable rebate (i.e. effectively resulting in a higher APR). This is very similar to the “Effective APR” disclosure requirement in Ontario. Note: the legislation is unclear regarding whether this requirement also applies to lease agreements. We are hoping for clarification from the New Brunswick regulators in this regard.
The legislative provisions regarding advertising for fixed credit, leases and interest-free periods are very similar to the requirements in Ontario.