CFPB Monitor News Guidance Perspectives of CFPB | Ballard Spahr Law Firm Blog

Tag Archives: credit card

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 >