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A “Bad Apples” Database for Banks? Not So Fast.

Should banks, while guarding against rolling episodes of misconduct by bankers, have the ability to blackball employees from the banking industry? A “bad apples” database of bank employees who have acted improperly in prior...more

Assessing the Utility of CARD Act Disclosures

PLA has for many years posted elite academic research questioning the utility of CARD Act disclosures. For example, in 2013 we posted Regulating Consumer Financial Products: Evidence from Credit Cards by Sumit Agarwal from...more

Consumer Financial Protection Bureau Law Enforcement: An Empirical Review

PLA today augments its popular UDAAP Enforcement Action Database page with a link to “Consumer Financial Protection Bureau Law Enforcement: An Empirical Review,” by Professor Christopher L. Peterson. We hope you find it...more

6/15/2016  /  CFPB , UDAAP

The Consumer Credit Card Market

Credit cards are central to the financial lives of most American consumers. Credit cards represent a key medium for U.S. consumer spending. In the first six months of 2015 alone, there were some 14.5 billion U.S. general...more

Excerpts from First Data S-1

PLA today posts two excerpts from the First Data S-1 that give interesting overviews of the payments ecosystem from First Data’s perspective, as well as a list of certain First Data alliances and related arrangements....more

On the Reidentifiability of Credit Card Metadata

PLA today posts a link to “Unique in the Shopping Mall: On the Reidentifiability of Credit Card Metadata,” which concludes that card transaction data that was anonymized in conventional ways (e.g., by removing names and...more

Co-branding Credit Cards with Charities: Commercial Co-Venture Issues

A cobranded credit card program in which the “merchant” is in fact a charity may be subject to special rules relating to the regulation of “commercial co-ventures” (also known as “cause-related marketing”). Issuers and...more

Federal Financial Institutions Examination Council Releases Cybersecurity Assessment Results: Boards of Directors and Senior...

The Federal Financial Institutions Examination Council (FFIEC) released general observations yesterday from a cybersecurity assessment of over 500 community financial institutions. The cybersecurity assessment evaluated the...more

CFPB Proposes No-Action Letter Policy for Innovative Products

The Consumer Financial Protection Bureau has proposed a no-action letter policy under which the agency would issue letters stating that its staff “has no present intention to recommend initiation of an enforcement or...more

Failure of Mandated Disclosures

PLA often posts links to scholarly articles assessing or speculating about the effectiveness, from a consumer-protection standpoint, of disclosure and other regulatory regimes. Past such posts include, for example,...more

New Form Factors in Cobrand and Private-Label Credit Card Program Agreements

Most current cobrand and private-label agreements involve one or, more usually, two parties that are issuing, branding or developing non-traditional form factors alongside or in lieu of plastic cards. Some of these form...more

College Debit Cards

PLA today posts the GAO’s report, issued last month, analyzing the market for college debit cards and expressing concern about “students’ access to no-fee ATMs, schools’ influence over students’ banking and payment choices,...more

3/7/2014  /  Colleges , Debit Cards , GAO , Students

Culture Shock: A Retailer’s Initial Lending Program With a Bank

Many retailers and OEMs have engaged banks to provide private-label credit to their individual and small-business customers, or have joined with banks in offering them cobranded general-purpose credit. Many other...more

12/6/2013  /  Banks , Lending , OEM , Retailers , Small Business

The Use of Consumer Reports in Online Marketplaces

Online marketplaces increasingly use consumer reports to match consumers with retailers that offer products and services that may be of interest to them....more

7/31/2013  /  FCRA , Online Platforms

Authorities Regarding GLBA Privacy and the FCRA

One of PLA’s missions is to facilitate knowledge-management for payments practitioners. Pursuant to that mission, PLA is today posting four fundamental, but not always easily accessed, authorities regarding GLBA privacy and...more

3/21/2013  /  FCRA , GLBA Privacy

Portfolio Finance Reference Materials

PLA today posts the public version of the agreement pursuant to which Chase invested in the Target card portfolio in 2008. Although no longer in effect, this agreement may be a source of useful ideas for future...more

12/5/2012  /  JPMorgan Chase
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