CFPB Tells Large Credit Card Issuers to Get in Line With TILA

Cozen O'Connor
Contact
LinkedIn
Facebook
X
Send
Embed

Cozen O'Connor

  • The CFPB issued a final rule to address late fees charged by “larger card issuers”—credit card issuers that together with their affiliates have one million or more open credit card accounts—to ensure compliance with the Truth in Lending Act’s (TILA) reasonable fee requirements.
  • The final rule adopts a late fee safe harbor threshold of $8, eliminates a higher late fee safe harbor dollar amount for the same violations during the same billing cycle or the next six billing cycles, ends automatic inflation adjustments for the $8 safe harbor late fee, and requires larger card issuers to prove a higher threshold fee is necessary to cover their actual collection costs before they charge such higher fees.
  • The effective date of the final rule will be 60 days after publication of the rule in the Federal Register.
Send Print Report

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.

© Cozen O'Connor | Attorney Advertising

Written by:

Cozen O'Connor
Cozen O'Connor
Contact
more
less

Cozen O'Connor on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign Up Log in
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide