agreement

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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