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. This article describes recent trends in regulatory, enforcement, and class action activity. It also suggests certain areas on which to focus compliance resources, and provides some general risk mitigation strategies for industry participants to consider in light of the increased risks they face.
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.
Firefox recommends the PDF Plugin for Mac OS X for viewing PDF documents in your browser.
We can also show you Legal Updates using the Google Viewer; however, you will need to be logged into Google Docs to view them.
Please choose one of the above to proceed!
LOADING PDF: If there are any problems, click here to download the file.
Consumer Protection Updates, Finance & Banking Updates
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.
© Benjamin Saul, BuckleySandler LLP | Attorney Advertising