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Category Archives: Credit Cards

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CFPB launches another credit card review

Posted in Credit Cards

The CFPB has issued another request for information about the credit card market.  The request is intended to inform the CFPB’s biennial review of the credit card market mandated by the CARD Act.  In October 2013, the CFPB issued its first report to Congress on the results of its first review.  In that report, the CFPB… More >

CFPB proposes temporary suspension of TILA requirement for credit card issuers to submit card agreements quarterly

Posted in Credit Cards

The CFPB has issued a proposal to suspend for one year the Truth in Lending Act/ Regulation Z requirement for issuers of open-end credit cards to send their credit card agreements to the CFPB quarterly for posting in a public database on the CFPB’s website.  The suspension would not affect the TILA/Reg Z requirement for such… More >

CFPB announces new Project Catalyst project

Posted in Credit Cards

The CFPB has announced a new project as part of its Project Catalyst initiative, which the CFPB describes as ” designed to encourage consumer-friendly developments in markets for consumer financial products and services.”  The new project is a research pilot to examine the effectiveness of early intervention credit counseling for consumers who are at risk… More >

CFPB issues bulletin on UDAAP risks in marketing credit card promotional APR offers

Posted in Credit Cards, UDAAP

The CFPB has issued a bulletin warning credit card issuers that offer certain promotional APRs of the risk that they may be engaging in deceptive and/or abusive acts or practices when making solicitations for such offers even if such solicitations are in compliance with Regulation Z.   The bulletin focuses on promotional offers that allow consumers… More >

Trade group criticizes CFPB reliance on enforcement and informal guidance

Posted in CFPB Enforcement, Credit Cards, Fair Lending

The U.S. Chamber of Commerce’s Center for Capital Markets Competitiveness has sent a detailed letter to Director Cordray in which it criticizes the CFPB’s approach of “regulation by enforcement settlement combined with issuance of brief guidance statements” in lieu of engaging in rulemaking or otherwise soliciting public input.  In the letter, the Chamber expresses its strong… More >

CFPB advises consumers on deferred interest credit cards

Posted in Credit Cards

The CFPB recently published a blog post to tell consumers what they “need to know” about deferred interest credit cards offered by health care providers.  The  CFPB states in the blog post that, because health care providers do not always explain how such cards work, the CFPB wants to “make sure” consumers are getting the… More >

CFPB calls for public disclosure of campus financial product marketing agreements

Posted in Credit Cards, Debit Cards, Deposit Accounts, Prepaid Cards

The CFPB wants financial institutions to post on their websites their marketing agreements with colleges and universities for financial products other than credit cards, such as deposit accounts, prepaid cards and financial aid disbursement accounts.  Pursuant to the CARD Act, card issuers must submit their campus credit card agreements annually to the CFPB together with… More >

Director Cordray confirms CFPB plans to examine credit card rewards programs

Posted in Credit Cards

According to a Bloomberg report by Carter Dougherty, Director Cordray confirmed last week that the CFPB will be looking at credit card rewards programs.  Director Cordray is reported to have indicated that the CFPB will be focusing on rewards program disclosures and considering the need for additional protections.   The Bloomberg report also indicated that, according to… More >

Credit card issuers can expect continued CFPB scrutiny

Posted in Credit Cards

The CFPB is keeping the heat on credit card issuers.  While subtitled “A review of the impact of the CARD Act on the consumer credit card market,” the CARD Act report issued yesterday by the CFPB contains more than the CFPB’s impact findings.  Most notably, the report also describes the CFPB’s plans to scrutinize add-on… More >

CFPB to hold credit card field hearing

Posted in CFPB General, Credit Cards

Yesterday the CFPB announced that it would hold a field hearing on credit cards in Chicago on October 2, 2013. The hearing will be held at the Harold Washington Library, located at 400 South State Street, and will commence at 11:00 a.m. CFPB Director Cordray plans to make an appearance, and testimony will be taken… More >

CFPB to hold September 30 forum on financial products marketed to college students

Posted in Credit Cards, Debit Cards, Deposit Accounts

On September 30, 2013, the CFPB will hold a forum in Washington, D.C. on financial products marketed to college students.  In January 2013, the CFPB issued a notice asking for input on a variety of issues with regard to these products, including the information shared between schools and financial institution providers, the way these products are… More >

CFPB eliminates independent ability-to-pay requirement for credit card applicants 21 or older

Posted in Credit Cards

The CFPB has amended Regulation Z to remove the requirement that a card issuer must consider the independent ability to pay of an applicant who is 21 or older.  The final rule, which will be effective upon publication in the Federal Register, retains the independent ability-to-pay requirement for applicants under the age of 21.  Issuers… More >

CFPB wants information about the CARD Act’s impact

Posted in Credit Cards

The CFPB is seeking information on how the CARD Act amendments to the Truth in Lending Act have impacted consumers and the credit card industry. Signed into law in 2009 and implemented through a series of changes to Regulation Z that became effective in three stages spanning August 2009 to October 2011, the CARD Act… More >

CFPB proposes amending credit card ability-to-pay rule

Posted in Credit Cards

The CFPB has released its proposed ability-to-pay rule. The proposed rule would amend the section of Regulation Z that currently provides that a credit card issuer must not open a credit card account or increase any limit on the account unless the card issuer considers the consumer’s independent ability to make the required minimum periodic… More >

Some observations on the CFPB’s $112.5 million settlement with American Express

Posted in CFPB Enforcement, Credit Cards

In another demonstration of aggressive enforcement, the CFPB, on October 1, announced that it had settled its enforcement actions against various American Express entities alleging a wide range of compliance violations.   The settlement requires American Express Bank, FSB and American Express Centurion Bank to make restitution payments totaling $85 million.  In addition, the banks, their… More >

Is the CFPB using its enforcement tool as de facto rulemaking?

Posted in CFPB Rulemaking, Credit Cards

Overshadowed by the publicity surrounding the announcement of the CFPB’s settlement of its first enforcement action was the CFPB’s concurrent release of a bulletin providing general guidance on marketing credit card add-on products. While focused on credit card add-on products, the bulletin is also intended to serve as guidance for the marketing of similar products… More >

Initial analyses of CFPB complaint data show misleading nature of data

Posted in CFPB General, Credit Cards, Hot Issues

Recall that when the CFPB launched the Consumer Complaint Database, its expressed hope that “the marketplace of ideas” – i.e., the public – would study and analyze the information disclosed in the database in order to “determine what the data show[s].” 77 FR 37559. The CFPB also stated that the purpose of the database is… More >

CFPB launches consumer complaint database

Posted in CFPB General, Credit Cards, Hot Issues

Today, the Consumer Financial Protection Bureau launched its Consumer Complaint Database, which allows the public to view consumer complaints filed against credit card issuers. The Bureau also announced that it is submitting a request to the Federal Register seeking comments on extending the database to include other financial products in addition to credit cards –… More >

CFPB suggests possible interim fix for credit card ability-to-pay rule concerns

Posted in CFPB Rulemaking, Credit Cards

Testimony to Congress earlier this week from Gail Hillebrand, CFPB Associate Director for Consumer Education and Engagement, seems to suggest a way for card issuers to deal with concerns about the Reg. Z rule that the Fed adopted to implement the CARD Act’s ability-to-pay requirement, at least while the CFPB considers whether to change the rule. As… More >