News & Analysis as of

Final Rules Regulation Z Credit Cards

Latham & Watkins LLP

Texas Judge Halts CFPB Rule Limiting Credit Card Late Fees

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The preliminary injunction was granted pursuant to Fifth Circuit precedent that the CFPB’s independent funding structure is unconstitutional. On May 10, 2024, the US District Court for the Northern District of Texas...more

Kilpatrick

Consumer Financial Protection Bureau Releases Final Rule Limiting Credit Card Late Fees

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In March the Consumer Financial Protection Bureau (CFPB) announced a final rule intended to limit late payment fees on consumer credit cards distributed by the larger credit card issuers (the “Final Rule”). The Final Rule,...more

Ballard Spahr LLP

Operational impacts of the new CFPB Credit Card Late Fee Rule

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On March 5, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued its final credit card late fee rule (the “Final Rule”), which, amongst other things, significantly reduces the late fee safe harbor cap for issuers...more

Morrison & Foerster LLP

CFPB Issues Final Rule to Reduce Credit Card Late Payment Fees

On March 5, 2024, the Consumer Financial Protection Bureau (CFPB) announced the issuance of its final rule to amend Regulation Z and further restrict credit card late payment fees (the “Final Rule”). With certain material...more

Goodwin

The CFPB’s Final Rule Imposes Significant Restrictions on Credit Card Late Fees

Goodwin on

On Tuesday, March 5, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule (Final Rule) which amends provisions of Regulation Z, which implements the Truth in Lending Act (TILA). ...more

Orrick, Herrington & Sutcliffe LLP

CFPB lowers most credit card late fees to $8, amending Regulation Z

On March 5, the CFPB announced a final rule that will amend TILA Regulation Z and lower the typical credit card late fees from $30 to $8. According to the final rule, the CFPB determined that the Regulation Z §1026.52(b) $30...more

Cooley LLP

CFPB Issues Final Rule to Reduce Credit Card Late Fees to $8 for Large Credit Card Issuers

Cooley LLP on

On March 5, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending provisions in Regulation Z that govern credit card late fee charges. The final rule follows the March 2023 release of the proposed...more

Cadwalader, Wickersham & Taft LLP

CFPB Finalizes Rule to Limit Credit Card Late Fees to $8

On March 5th the Consumer Financial Protection Bureau ("CFPB") announced that it had finalized its rule revisions to Regulation Z and the Official Staff Commentary regarding “Credit Card Penalty Fees.” See a redline of the...more

Husch Blackwell LLP

The CFPB Drastically Cuts The Safe Harbor Amount For Credit Card Late Fees

Husch Blackwell LLP on

After much anticipation, the Consumer Financial Protection Bureau (CFPB) has issued a final rule drastically reducing Regulation Z’s safe harbor fee amount for credit card late fees to $8 for card issuers that do not qualify...more

McGlinchey Stafford

“Junk Fee” Revolution Continues: CFPB Issues Final Rule Limiting Late Fees on Credit Cards

McGlinchey Stafford on

Tuesday, the Consumer Financial Protection Bureau (CFPB) issued a Final Rule capping most credit card late fees at $8. The CFPB believes its new rule may save consumers more than $10 billion a year in late fee charges for an...more

Ballard Spahr LLP

CFPB annual CARD Act, HOEPA, QM adjustments do not include credit card penalty fees safe harbors (UPDATED)

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The CFPB recently posted on its website a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified...more

Morrison & Foerster LLP

What To Know About CFPB's New Prepaid Card Rule

The Consumer Financial Protection Bureau issued its final rule to amend provisions of Regulation E and Regulation Z to further regulate prepaid card products, or “prepaid accounts.” As discussed below, the rule generally...more

Morrison & Foerster LLP

DOD Adopts Sweeping Changes to Rules Implementing Military Lending Act Provisions

On July 21, 2015, the Department of Defense (DOD) adopted sweeping changes to its rules that implement the Military Lending Act (MLA). The amended rules significantly expand the scope of the MLA provisions by covering both...more

Ballard Spahr LLP

CFPB finalizes temporary suspension of TILA requirement for quarterly submission of credit card agreements

Ballard Spahr LLP on

The CFPB has issued a final rule adopting its proposal to suspend for one year the Truth in Lending Act/Regulation Z requirement for issuers of open-end credit cards to send their credit card agreements to the CFPB quarterly...more

Ballard Spahr LLP

CFPB eliminates independent ability-to-pay requirement for credit card applicants 21 or older

Ballard Spahr LLP on

The CFPB has amended Regulation Z to remove the requirement that a card issuer must consider the independent ability to pay of an applicant who is 21 or older. The final rule, which will be effective upon publication in the...more

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