Wednesday, March 18, 2015

CFPB is Seeking Public Comment Regarding the Credit Card Market

The CFPB has submitted a Request for Information regarding the credit card market.  The comment period will remain open for sixty (60) days once it is published in the Federal Register.  Under the CARD Act, the CFPB is required to review the credit card market every two years.  The Request for Information focuses on: (a) the impact the CARD Act has had on credit card products, (b) specific terms, disclosures and products and (c) delinquent debt and the collection of the same.  The focus of the Request for Information and the resulting comments will likely provide insight as to whether further regulations will be forthcoming as to credit card products and if so, what the focus is likely to be.

The Request seeks comments as to the following:

The Impact of the CARD Act:

  • How have credit card agreements changed in the past two years, particularly:
    • Their terms and conditions;
    • The length and complexity of the agreement; and
    • Changes in underwriting, marketing and pricing practices
  • How effective are current disclosures; and
  • The cost and availability of credit.

Specific Terms, Disclosures and Products:

  • Are effective disclosures being provided to customers using mediums other than paper statements;
  • Are reward programs providing adequate disclosures;
  • Are payment grace periods being disclosed in a meaningful manner;
  • The impact of fee harvesting practices which are not covered by the CARD Act; and
  • How well do consumers understand deferred interest products and the impact of those products on subprime consumers

Delinquent Debt and Collection

  • What practices are used to minimize loss prior to charge off;
  • How are ability to pay standards being implemented in approving credit applications and increasing credit lines;
  • How are relationships with collection agencies managed; and
  • To what extent are charged off portfolios sold to debt buyers and the terms of sale
The full text of the Request for Information as submitted to the Federal Register can be found here:


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