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Financial Services Law Insights and Observations

CFPB Seeks Public Input on Impacts of CARD Act

Credit Cards CFPB

Consumer Finance

On December 19, the CFPB issued a notice and request for information about the impact of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act or Act) on the consumer credit card market. The request seeks information about: (i) how the CARD Act has changed the substantive terms and conditions of credit card agreements, (ii) the effectiveness of disclosure of terms, fees, and other expenses of credit card plans, (iii) the adequacy of protections against unfair or deceptive acts or practices relating to credit card plans, and (iv) whether the Act has affected the cost and availability of credit, the safety and soundness of any credit card issuers, the use of risk-based pricing, or the innovation of new products. The CFPB explained that it will use the data gathered to prepare a publicly available report to Congress on the state of the consumer credit card market, and to inform future policy decisions regarding credit cards. The CFPB will accept comments for 60 days following publication of the notice in the Federal Register.