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In today’s podcast episode, we are joined by Raj Date, who has served in a variety of roles at the Consumer Financial Protection Bureau, including as the acting head of the agency and as it’s first-ever Deputy Director. He recently wrote a thought-provoking article in a new online publication, Open Banker, entitled “Banks Aren’t Over-Regulated, They Are Over-Supervised.”… Continue Reading

On August 8, 2024, the plaintiffs filed their brief in opposition to the CFPB’s motion to dissolve the preliminary injunction in the lawsuit challenging the CFPB’s credit card late fee final rule (“Rule”). In their brief, the plaintiffs renew their arguments that the CFPB exceeded its authority under Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) and the Truth in Lending Act (TILA) in promulgating the Rule.… Continue Reading

The Consumer Bankers Association has launched a four-part blog series “Facts Matter” to counter what it calls “misinformation conveyed by the CFPB” in its press release about the CFPB’s October 2023 report (Report) under the Credit Card Accountability Responsibility and Disclosure Act (CARD Act).  The CARD Act requires the CFPB to issue a biennial report to Congress on the consumer credit card market.… Continue Reading

In a blog post that appeared last week, the CFPB reported on research into various factors considered significant in explaining current credit card interest rates.  The CFPB reported that over 175 million Americans have at least one credit card, half of which carry a balance that continues to accrue increasingly high interest rates. … Continue Reading

The CFPB has issued a new request for information about the credit card market that seeks comment on two related, but separate, reviews.  One review is a review of CARD Act rules pursuant to Section 610 of the Regulatory Flexibility Act, which requires the CFPB to review certain rules within 10 years of their publication and consider the rules’ effect on small entities.   … Continue Reading

The CFPB has issued its annual report on TILA, EFTA, and the CARD Act which covers activity in 2016 and 2017.  The report provides brief summaries of the 2016 and 2017 enforcement actions brought by the CFPB and other federal agencies with relevant enforcement authority and provides data on reimbursements required as a result of enforcement actions brought during these periods.… Continue Reading

The CFPB’s fourth biennial report on the credit card market was issued at the end of August.

The Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) requires the CFPB to perform periodic market reviews.  The CFPB’s first CARD Act report was issued in October 2013, its second report was issued in December 2015, and its third report was issued in December 2017. … Continue Reading

The CFPB published a request for information in yesterday’s Federal Register seeking information to inform its next review of the credit card market.  The CARD Act requires the Bureau to conduct such a review every two years.  The Bureau’s first three reviews were published in October 2013, December 2015, and December 2017.… Continue Reading

The CFPB released its sixth annual report to Congress on college credit card agreements.  The annual report is mandated by the CARD Act.

The CARD Act requires mandatory reporting to the CFPB by card issuers on agreements with institutions of higher learning or certain affiliated organizations (such as alumni associations).  The information in the report is current as of the end of 2016.… Continue Reading

The CFPB released its annual report on college credit card agreements (the fifth issued by the CFPB), together with a compliance bulletin regarding the obligation of colleges and universities under the CARD Act to publicly disclose their credit card marketing agreements.

Like the CFPB’s 2014 and 2015 annual reports, the new report consolidates the CFPB’s mandatory reporting under the CARD Act on college credit card agreements and “other information on financial products offered or marketed to students collected via our various market monitoring tools.” … Continue Reading