CFPB Initiates Second CARD Act Review

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On March 19, 2015, the Consumer Financial Protection Bureau (“CFPB”) published a notice and request for information (“2015 RFI”) regarding the impact of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“CARD Act”), as required by Section 502(a) of the CARD Act. The CARD Act requires that the CFPB conduct this review every two years; the last such effort was undertaken beginning in late 2012 (“2012 RFI”).

In announcing this initiative, CFPB Director Richard Cordray said, “With today’s inquiry, the Bureau is seeking to further understand how the credit card market is working in practice and how credit card protections affect consumers and credit card issuers.” The information collected will form the basis of a CFPB report to Congress on the state of the consumer credit card market, and will be used by the CFPB to “inform future policy decisions on the topic.”

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