NAFCU letter to CFPB on the credit card market

(May 18, 2015) —

Ms. Monica Jackson
Office of Executive Secretary Consumer Financial Protection Bureau 1700 G Street NW
Washington, D.C. 20552

RE: Request for Information Regarding Credit Card Market (Docket No. CFPB-2015-0007) Dear Ms. Jackson:

On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents federal credit unions, I write to you regarding the Consumer Financial Protection Bureau’s (CFPB) request for information regarding the credit card market. See 80 FR 14365 (March 19, 2015). NAFCU, in an effort to assist the CFPB in conducting its market review, sought feedback from its member credit unions on their experience since the implementation of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) and would like to bring the following matters to the CFPB’s attention.

General Comments

The passage of the CARD Act was intended to “establish fair and transparent practices related to the extension of credit” in the credit card market. The CARD Act brought sweeping changes to the field of credit card lending, most notably limiting the types of fees and rate increases that may be charged to consumers, requiring issuers to assess a consumer’s ability-to-pay prior to the extension of credit, and mandating new simplified disclosures to bolster consumer awareness. As part of the CARD Act, Section 502(a) requires the CFPB to conduct a review of the consumer credit card market every two years. In order to complete this review, the Bureau has solicited comment from industry participants about the status of the credit card market and the effects of the CARD Act.

NAFCU and its member credit unions have long supported providing consumers with fair and transparent financial products. Credit unions have always been good actors in the credit card market and constantly strive to provide their members with credit card products that best fit the Consumer Financial Protection Bureau member’s individual financial needs and goals. However, it is undeniable that the CARD Act has required credit unions to change the way they approach the credit card market.

Click here for complete PDF of Credit Card Market Review.

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