CBA Submits Joint Trades Comment Letter on the CARD Act RFI

On Thursday, June 8, 2017, CBA and the Financial Services Roundtable submitted a joint comment letter in response the CFPB’s request for information on the state of the consumer credit market. The CFPB is required under the Credit Card Accountability Responsibility and Disclosure Act (CARD Act) of 2009 to conduct a review of this market on a biennial basis. In our letter, the Associations addressed, among others, the following issues:


  • Online and Mobile Account Servicing: Online and mobile banking provide consumers with on-demand access to their credit card accounts using their preferred digitally-enabled device. We urge the CFPB to support digital banking and make it easier for consumers sign-up for electronic statements and disclosure.


  • Rewards Products: Credit card rewards programs are an example of effective self-regulation that shows consumer welfare and protection does not necessarily call for regulatory intervention.


  • Innovation: Card issuers are developing new technologies to better serve consumers, while implementing security measures to keep their accounts safe. At the same time, disruptive innovations are changing and challenging the way industry conducts business.


  • Debt Collection: Rules should ensure consumers are treated fairly and respectfully, but they should not unduly restrict the ability of issuers to communicate with delinquent borrowers.