CFPB seeks feedback on credit cards

Agency Rule-Making & Guidance Federal Issues CFPB Consumer Finance Credit Cards CARD Act UDAAP

On January 24, the CFPB issued a notice and request for information (RFI) seeking public feedback on several aspects of the consumer credit card market in accordance with Section 502(b) of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act). The CARD Act was enacted by Congress to establish fair and transparent practices related to the extension of credit within the credit card market, and requires the Bureau to undertake a biennial review of the industry to determine whether regulatory adjustments are needed. The Bureau said it plans to publish its report to Congress later in 2023.

The RFI covers several broad topics ranging from lending practices to the effectiveness of rate and fee disclosures, and seeks comments on the experiences of consumers and credit card issuers in the credit card market, as well as on the overall health of the credit card market. Specifically, the RFI requests feedback on issues related to:

• Credit card agreement terms and credit card issuer practices;
• The effectiveness of issuers’ disclosure of terms, fees, and other expenses of credit card plans;
• The adequacy of protections against unfair or deceptive acts or practices relating to credit card plans;
• The cost and availability of consumer credit cards;
• The safety and soundness of credit card issuers;
• The use of risk-based pricing for consumer credit cards; and
• Consumer credit card product innovation and competition

Comments on the RFI are due April 24. The Bureau noted in its announcement that it also issued market-monitoring orders to several major and specialized credit card issuers seeking information on various topics, including major credit card issuers’ practices related to, among other things, applications and approvals, debt collection, and digital account servicing.