On July 18, 2012, the Consumer Financial Protection Bureau (CFPB) and the Office of the Comptroller of the Currency (OCC) announced a joint enforcement action against Capital One Bank (USA) N.A. arising from sale of “add-on products” in connection with newly issued credit cards, including “credit protection” and “identity monitoring” services. Those add-on products were allegedly marketed to consumers with low credit scores or low credit limits by directing them to a third-party call center at the time the consumers sought to activate their credit cards. It was during these calls that the third-party vendors allegedly used high-pressure sales tactics and made materially false, deceptive, or otherwise misleading oral statements relating to the cost, coverage terms, benefits, and other features of the add-on products that allegedly led consumers to purchase them. Similarly, when these consumers sought to cancel their purchases, they were allegedly routed to these third-party vendors who used the same allegedly deceptive marketing tactics to convince the consumers to keep paying for the add-on products. In addition, consumers were allegedly charged the full fees for these products while they were in a pending status waiting for their credit card application to be approved. Among other things, the settlement is noteworthy because it is the first enforcement action by the CFBP and contradicts the government’s past rhetoric that the establishment of the CFPB would not subject financial institutions to duplicative oversight.