DWT and the Financial Services Roundtable jointly presented a webinar on the CFPB’s latest CARD Act Report and its potential impact on the credit card market in January 2015. In case you missed it (or want to listen again), a recording of the webinar is now available by clicking here.
DWT Payments team members Andy Owens and Adam Maarec were joined by Rich Foster, Senior Vice President and Senior Counsel for Regulatory and Legal Affairs at the Financial Services Roundtable and Jeff Bloch, Vice President and Deputy Director at US Bank. They explored concerns expressed by the CFPB, including not only such “headline” issues as rewards features and terms and deferred interest products, but also the many other concerns called out at various points in the lengthy Report.
Our summary of the Report is available here and a few of the specific page numbers we mentioned or referenced during the webinar appear below.
|Focus on rewards-based marketing||228|
|Vague rewards disclosures||214, 232|
|Rewards as a “limited purpose asset account”||229|
|Rewards earning and redemption||233, 234|
|“Social optimality” of rewards and interchange||211|
|Comparing 0% and deferred interest APRs||202|
|Deferred interest “ability to pay gap”||205|
|Disclosure of trailing interest||128, 130|
|Grace periods and promotional offers||126|
|Concerns with paperless statements||134|
|Impact of market-based rate increases||83, 84|
We hope PLA readers find this information useful.