Credit Cards

Subscribe to Credit Cards via RSS

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 offered in connection with other forms of credit or deposit services. … Continue Reading

TransparencyRecall 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 to “provide consumers with timely and understandable information to make responsible decisions about financial transactions and to enhance the credit card market’s ability to operate transparently and efficiently.” … Continue Reading

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 – any such comments are due by July 19, 2012.… Continue Reading

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.… Continue Reading

On January 30, 2012, the American Bankers Association delivered a comment letter  to the CFPB in which it expressed strong disagreement with the CFPB’s proposed policy statement on “Disclosure of Certain Credit Card Complaint Data“. The ABA expressed concern that the complaint data will not help and may actually mislead consumers because it is “incomplete, unrepresentative, and unverified.”… Continue Reading

The CFPB has released an updated version of its Company Portal Manual that describes the operation of the portal through which companies can view and respond to consumer complaints submitted through the CFPB’s complaint system (which the CFPB plans to expand beyond complaints about credit cards and mortgages to include complaints about other products such as deposit accounts.)… Continue Reading

 It’s not often that Barney Frank agrees with the American Bankers Association but, when it comes to Regulation Z’s ability to pay rule for credit cards, it seems that Representative Frank now thinks the ABA got it right and the Fed got it wrong. The Reg. Z rule, adopted by the Fed in final form in March 2011 to implement the Credit CARD Act and effective October 1, requires issuers to consider an applicant’s independent ability to pay, regardless of the applicant’s age.… Continue Reading

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 draft utterly fails to comply with the increasingly elaborate and complex regulatory requirements that have contributed greatly over the years to the length and complexity of cardholder agreements.… Continue Reading

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. … Continue Reading