CFPB Launches Inquiry Into Financial Products Marketed through Higher Learning Institutions

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On January 31, the CFPB issued a notice and request for comment about how current and future arrangements between institutions of higher education and financial institutions could be structured “to promote positive financial decision-making among young consumers.” The inquiry also is designed to help the CFPB “develop a clearer picture of the financial products and services that are being offered to college students, as well as consumers’ experiences using those products and services.” Specifically, with regard to campus affinity relationships, the CFPB wants to know, among other things, (i) what types of campus affinity products are being offered to students, what features do they have, how are they being marketed, and what are their terms and conditions, including fees, (ii) what information about students is being provided to the education institution, (iii) the nature and volume of student complaints, (iv) what benefits are education institutions realizing through affinity relationships, and (v) the extent to which these products are bundled with student identification cards. The CFPB also seeks similar information about other financial products marketed to students. The CFPB is seeking comments from various stakeholders, including students, institutions of higher education, and financial institutions by March 18, 2013.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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