CARD Act

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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

The CFPB has issued its second biennial report on the credit card market.  In addition to setting forth the CFPB’s general findings about market conditions, the report discusses “areas of concern for consumers,” including deferred interest products, subprime credit cards, and rewards programs.  The areas of concern noted in the report are likely to be the subject of heightened CFPB supervisory scrutiny and enforcement activity. … Continue Reading

Today, the CFPB entered a consent order that requires subprime credit card company, Continental Finance Company, LLC (“Continental”), to refund an estimated $2.7 million to consumers who were charged alleged illegal credit card fees. The consent order also imposes a civil penalty on Continental in the amount of $250,000.

In the consent order, the CFPB found that Continental required cardholders to pay fees during the credit card account’s first year that exceeded 25% of the account’s initial credit limit, in violation of the Credit Card Accountability, Responsibility, and Disclosure Act of 2009 (the “CARD Act”).… Continue Reading

The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank.  The adjustments made by the final rule are effective January 1, 2015. 

The CARD Act requires the CFPB to calculate annual adjustments of (1) the minimum interest charge threshold that triggers disclosure of the minimum interest charge in credit card applications, solicitations and account opening disclosures, and (2) the fee thresholds for the penalty fees safe harbor. … Continue Reading

The CFPB is keeping the heat on credit card issuers.  While subtitled “A review of the impact of the CARD Act on the consumer credit card market,” the CARD Act report issued yesterday by the CFPB contains more than the CFPB’s impact findings.  Most notably, the report also describes the CFPB’s plans to scrutinize add-on products, deferred interest programs, rewards programs and other “areas of concern.” … Continue Reading

Credit CardsThe CFPB is seeking information on how the CARD Act amendments to the Truth in Lending Act have impacted consumers and the credit card industry. Signed into law in 2009 and implemented through a series of changes to Regulation Z that became effective in three stages spanning August 2009 to October 2011, the CARD Act imposed significant new restrictions on credit card pricing practices.… 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

 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