Yesterday, the Consumer Financial Protection Bureau (“CFPB”) released the “CARD Act Report,” a report summarizing the CFPB’s views on the impact of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“CARD Act” or “Act”) on the consumer credit card market (“Report”). The Report was issued pursuant to Section 502(a) of the CARD Act, which mandates that the CFPB conduct a biennial review of the consumer credit card market, including the effect of the Act on the cost and availability of credit and the adequacy of protections for credit cardholders. With the Report, the CFPB signals that it has concerns about four features found in the consumer credit card market: deferred interest programs, online disclosures, rewards programs and grace periods. The CFPB also highlights continuing concerns about the offering of add-on products and pre-account opening fees.
In a press release accompanying the Report, CFPB Director Richard Cordray states that “[t]he CARD Act brought better consumer protections and fairness to the marketplace, but we found there is more work to be done.” The CFPB states that the Report draws upon publicly and commercially available data, as well as data obtained by the CFPB through its supervision of large credit card issuers.
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