American Financial Services Association

AFSA Responds to CFPB’s RFI on the CARD Act

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AFSA Responds to CFPB’s RFI on the CARD Act

This week, the American Financial Services Association (AFSA) commented on the Consumer Financial Protection Bureau’s (CFPB) request for information (RFI) on the economic impact of the Credit Card Accountability and Disclosure (CARD) Act and the agency’s review of the consumer credit market. AFSA specifically addressed the current relevance of the CARD Act (enacted in 2009) and whether this statute has been beneficial to consumers in the credit card market. In its comments, AFSA emphasized that additional restrictions and requirements on consumer credit card lending will adversely affect consumers and lenders by increasing costs for both parties, discouraging the entry of new lenders into the market, and accelerating lender consolidation.

With regards to the CARD Act’s relevance, AFSA noted that consumer choice in the credit card marketplace has significantly increased since the law’s enactment through new forms of credit and payment products and app-based payment services offered by fintechs and traditional financial services companies. Finally, AFSA commented on the current state of credit card agreements, Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) protections under the CARD Act, and the use of risk-based pricing in reviewing the credit card market.

October 28th, 2020 by