Mar 16

Recent Compliance Issues: 2/20/15 – 3/5/15


1. Credit card issuers are extending the length of promotional, interest rate periods for balance transfers, according to a CardHub survey of 15 major issuers. Citigroup, Discover, and PNC Bank cards offer zero-percent interest for 18 months, charging a three percent fee for transfers. JPMorgan Chase has a zero-percent interest offer for 15 months with no transfer fee. The Consumer Financial Protection Bureau (CFPB) issued a bulletin on September 24, 2014 to inform credit card issuers of the risk of engaging in unfair and deceptive and/or abusive acts and practices (UDAAP) in connection with solicitations that offer a promotional annual percentage rate (APR) on a particular transaction over a defined period of time. Let our former, Federal regulators review your solicitation activities to ensure that they avoid any UDAAP violations.

2. Earlier this week, CFPB Director, Richard Cordray, expressed support for his agency’s efforts to regulate overdraft fees during his semi-annual appearance before the House Financial Services Committee. But some lawmakers feel that the agency is overstepping its bounds in this area and that consumer protection should mean respect for the consumer’s right to make important economic choices, free from an interfering government. However, if your institution offers courtesy overdraft services, let our seasoned, former, Federal Regulators review your overdraft program activities for compliance with existing and current regulations and guidance.