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MJB, I can't really answer your question, because I have never had to request. JCP CLI's me every three months whether I need it or not. They have been an amazing builder card; although I don't care for GEMB in theory, they have been very good to me.
CLI's are always about $300 for me. I went from $500 to $2600....ummm..in about 2 years,maybe?
Hope this helps somewhat.
I believe JC Penny is backed by GEMB. So, you should be able to hit the luv button after the 4th statement cuts.
Tricky part is that they won't cut a statement unless there has been activity on the account.
Just passed my 4 month payment history mark on JCP/GEMB account (card opened late August) and hit the CLI button; No Go. Called in this morning and after speaking with Credit CSR was transferred to underwriting. Was told the company policy has changed, no longer approving CLI's after 4 month internal history. They will pull a hard for each requested CLI. I asked are you still doing auto CLI's and if yes, at what mark? She said she didn’t know, it would be done randomly, but as of today, she can't really say when.
It's getting chilly out here!! Reps and Analysts very nice, extremely accommodating....but their hands are tied. Weathering out the storm (both figuratively and literally) here in NJ. Glad I chose to aggressively build credit portfolio early 2008, the pocketbooks are definitely now shut!! But YMMV....
Good luck all!