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Valerie Hletko Quoted in Bank Safety & Soundness Advisor Article, "CFPB Sees New UDAAP Violations in Card Balance Transfer Offers"

Valerie L. Hletko

Valerie Hletko was quoted in the September 22, 2014 Bank Safety & Soundness article, "CFPB Sees New UDAAP Violations in Card Balance Transfer Offers."

“The bureau has been gaining focus on other aspects of credit card programs, such as rewards, in the supervisory context, and it is also clear it is very concerned about deferred interest programs,” said Valerie Hletko, a partner with Buckley Sandler in Washington. “The actual issue addressed in the bulletin is relatively narrow. It is clear that the bureau would like issuers to segregate balance segments for purposes of grace, so that customers not paying off a promotional balance do not lose the grace period with respect to new purchases.”

“What is particularly interesting about the bulletin,” Hletko said, “is that the bureau is saying, ‘We accept that all the disclosures provided in connection with these programs complied with Regulation Z. You made all the appropriate disclosures. But customers still did not understand the deal they were getting."