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Tag Archives: credit card

CFPB report highlights inadequate disclosure of campus financial products

Posted in Campus Financial Products

In its fifth annual report on college credit card agreements, the CFPB takes financial institutions as well as colleges and universities to task for failing to adequately disclose their marketing agreements for campus financial products.  The annual report is required by the CARD Act. The CARD Act requires institutions of higher education to disclose publicly… More >

CFPB sues company for alleged credit card sham

Posted in CFPB Enforcement

A new lawsuit filed by the CFPB alleges that a Texas-based company, Union Workers Credit Services, deceived consumers into paying fees to sign up for a “platinum card” that purported to be a general-use credit card but, in actuality, could only be used to buy products from the company.  The CFPB’s complaint, filed in a Texas… 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 >

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 >

Further thoughts on the bureau’s prototype credit card agreement

Posted in Credit Cards, Hot Issues

I share much of Chris’ reaction to the Bureau’s prototype cardholder agreement. The Bureau staff has labored mightily and has managed to produce an agreement that is six-(not two) pages of material. In considering the Bureau’s success or lack of success in producing a short cardholder agreement, it is important to note that the Bureau’s… More >

The Bureau’s 2+4 page prototype credit card agreement: simplification taken too far

Posted in Credit Cards, Hot Issues

On December 7, 2011, the CFPB released its “prototype” credit card agreement, cautioning that it is “not a model form” and that its use is “not mandatory.”  Although the prototype agreement is being referred to as a “2-page agreement,” it incorporates a series of definitions by reference that comprise a further 4 pages of text. … More >