CFPB proposes excluding credit card pre-account opening fees from 25% fee limit

The CFPB published a proposed amendment to Regulation Z (Truth in Lending) in the Federal Register on April 12 that would remove fees paid before a credit card account is open from the scope of the 25% limit on total fees that may be charged during the first year after account opening. The proposal also includes corresponding amendments to the Official Regulation Z Commentary. Comments on the proposal must be submitted by June 11, 2012. For more information on the proposal, see our legal alert.