On December 27, 2017, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) released its biennial report on the consumer credit card market (“2017 Report” or “Report”), which summarizes its views on the state of the consumer credit card market over the past two years. The Report is particularly noteworthy because it provides the first insight into the post-Cordray CFPB’s views on the state of the consumer credit card market.

The Report was issued pursuant to Section 502(a) of the CARD Act (“CARD Act”), which directs the CFPB to review and report on the consumer credit card market. The CARD Act requires the CFPB’s report to review specific certain topics, including terms of credit card agreements and issuer practices, the effectiveness of disclosures, the adequacy of consumer protections, and whether the CARD Act has impacted any of these areas. Prior CARD Act reports also have addressed other market developments, and the 2017 Report continues this trend.