Rick Fischer, Obrea O. Poindexter, and Jeremy R. Mandell
Banking + Financial Services, Financial Institutions + Financial Services, and Financial Services
On January 31, 2019, the Consumer Financial Protection Bureau (CFPB or Bureau) published a Request for Information (2019 RFI) regarding the consumer credit card market. In accordance with Section 502(a) of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Bureau conducts a biennial review of the consumer credit card market by soliciting public comment and feedback. In the past, the Bureau has used these reviews to help set the Bureau’s priorities as they relate to the consumer credit card market. The CFPB conducted its previous review in 2017, through its March 2017 RFI and the resulting 2017 CARD Act Report.
The CFPB uses these RFIs to gather feedback from participants in the consumer credit card market, including consumers, credit card issuers, and consumer advocates. Unlike the 2015 and 2017 RFIs, the 2019 RFI does not ask for comment on any “areas of further interest” to the Bureau. Instead, the 2019 RFI requests comment only on the specific topics required by the CARD Act. Nonetheless, the CFPB encourages commenters to address additional issues related to the consumer credit card market that they believe are worthy of the CFPB’s attention. Comments on the 2019 RFI are due by May 1, 2019.
The Bureau is seeking specific comment on the following topics.
The 2019 RFI is an opportunity for industry and the public to identify for the Bureau inefficiencies in the consumer credit card market, including as they relate to the ways that consumers are using credit cards through different technology channels. For example, the Bureau has indicated in prior rulemaking agendas an interest in pursuing disclosure modernization, which is a topic included in the 2019 RFI.
Contact our world-class financial services lawyers.
©1996-2019 Morrison & Foerster LLP. All rights reserved.