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Financial Services Law Insights and Observations

CFPB issues CARD Act RFI

Federal Issues CFPB RFI CARD Act Small Business Lending

Federal Issues

On August 25, the CFPB announced a Request for Information (RFI) on the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), consistent with the requirements of Section 610 of the Regulatory Flexibility Act (RFA), which specifies that agencies should review certain rules within 10 years of their publication to consider the rules’ effect on small businesses. Specifically, the Bureau is seeking comments from stakeholders on the economic impact of the CARD Act on small entities and whether regulations should be adjusted to address those impacts. Additionally, the RFI seeks information, pursuant to section 502(a) of the CARD Act, related to the consumer credit card market. Among other things, the Bureau requests stakeholders comment on (i) the terms of credit card agreements; (ii) the effectiveness of credit card disclosures; (iii) the cost and availability of credit cards; and (iv) credit card product innovation.

Comments on the RFI will be due 60 days after publication in the Federal Register.