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Late Fees Consumer Financial Products NPRM

Ballard Spahr LLP

The Once and Future Rule: How the CFPB’s Credit Card Late Fee Rule Compares to Regulation Z and the Previously Proposed Rule

Ballard Spahr LLP on

On March 5, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued its final credit card late fee rule (the “Final Rule”). The timing for publication of the final rule was widely perceived as coordinated with the...more

Orrick, Herrington & Sutcliffe LLP

CFPB proposal targets late fees on cards

On February 1, the CFPB issued a notice of proposed rulemaking (NPRM) to amend Regulation Z, which implements TILA, and its commentary to better ensure that late fees charged on credit card accounts are “reasonable and...more

Sheppard Mullin Richter & Hampton LLP

CFPB Examines Credit Card Late Fees

In 2009, Congress enacted the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act). Among other things, the CARD Act curtailed a range of junk fees, coercive contract clauses, and other suspicious...more

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