Bureau begins biennial review of consumer credit card market, invites public feedback

A request for information seeking public feedback on how the consumer credit market is functioning was announced Tuesday as part of the Consumer Financial Protection Bureau’s (CFPB) biennial review of the industry, with feedback due to the agency by April 24.

The biennial review is conducted in accordance with the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), which requires the CFPB to conduct a review of the credit card industry every two years and report to Congress. The last review was in 2020, with the report issued in 2021.

The bureau noted that the act requires the CFPB to undertake a comprehensive review of the entire industry to help determine whether regulatory adjustments are needed. “This review includes seeking public feedback as well as issuing market-monitoring orders to major credit card issuers to collect information on their business practices,” it said.

“The CFPB undertakes a biennial review of the consumer credit card market to ensure guidelines and guardrails to protect consumers are working as intended,” CFPB Director Rohit Chopra said in a statement with Tuesday’s release. “This request for information is a meaningful data point that will inform our decision-making on any potential changes, and the CFPB invites consumers, credit card issuers, industry analysts, consumer groups, and the general public to submit information and comments relevant to the topic.”

The CFPB said it wants to hear about people’s overall experiences with credit card products. Specific areas of interest noted – and the CFPB said this is not an exhaustive list – are:

  • Terms of credit card agreements and the practices of credit card issuers
  • Effectiveness of disclosure of terms, fees, and other expenses of credit card plans
  • Adequacy of protections against unfair or deceptive acts or practices relating to credit card plans
  • Cost and availability of consumer credit cards
  • Safety and soundness of credit card issuers
  • Use of risk-based pricing for consumer credit cards
  • Consumer credit card product innovation

A draft Federal Register notice, issued with Tuesday’s release, provides a more detailed description of the above-noted topics. For example, in seeking input on terms of card agreements and issuer practices, the bureau seeks input on how these things have changed over the previous two years and drills more deeply into more specific matters, such as supplementary card features; marketing practices and their impact on consumers’ ability to comparison-shop; practices that may uniquely affect certain populations, including servicemembers and their dependents, low- and moderate-income consumers, older Americans, and students; collections practices; use of electronic communications; and partnerships between card issuers and merchants.

The bureau said it has also issued market-monitoring orders to “a diverse group” of major and specialized credit card issuers. Those orders, it said, “seek information that no other data-gathering mechanisms currently address, such as the practices of major credit card issuers relating to, among other topics, applications and approvals, debt collection, and digital account servicing.”

The CFPB’s RFI is slated for publication in the Federal Register.

Feedback from consumers, industry, advocates will help inform biennial credit card market report

RFI notice prepared for Federal Register

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