Credit and Payment Cards in Focus: Regulatory, Enforcement, and Litigation Risk Update

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The risk of litigation for card issuers has been heightened by a proposed UDAP rule, issued by federal regulators, that breaks new ground by prohibiting a wide range of fees and finance-charge practices on cards. In addition, the Federal Reserve Bank of Boston has made public its study finding redlining by race in the availability of credit in certain communities. The authors suggest proactive strategies that card issuers should take to reduce enforcement and litigation risks.

This article was co-authored with Andrew L. Sandler and Molly A. Meegan and appeared in the Review of Banking and Financial Services, Volume 24, No. 9, and is reprinted with permission.

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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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