AFSA Comments on CFPB RFI re: the Consumer Credit Market

On June 8, the American Financial Services Association (AFSA) submitted a comment letter on the Consumer Financial Protection Bureau’s (CFPB) request for information (RFI) regarding the consumer credit card market. The letter notes that AFSA members view the credit card market as “healthy,” despite the huge investment made in 2009-10 to comply with the Credit Card Accountability Responsibility and Disclosure Act (CARD Act).

  • AFSA outlined comments on a variety of areas, including:Credit card agreements;
  • Adequacy of protections against unfair or deceptive acts or practices (UDAP) or unlawful discrimination;
  • Use of risk-based pricing;
  • Deferred interest products;
  • Rewards;
  • Variable interest rates, and;
  • Debt collection.

AFSA will continue to work with the CFPB as it studies the consumer credit market.