Letter to CFPB on the Request for Information Regarding Consumer Credit Card Market

CARD Act Rules RFA Review and Credit Card Market Review
Bureau of Consumer Financial Protection
1700 G Street, NW
Washington, D.C. 20552

Dear Sir or Madam:

The American Bankers Association, the Consumer Bankers Association, and the National Association of Federally-Insured Credit Unions (collectively, Associations) are pleased to submit our comments to the Request for Information of the Consumer Financial Protection Bureau (Bureau) regarding the consumer credit card market pursuant to the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act or the Act). Section 502(a) of the CARD Act requires the Bureau to conduct a review every two years of the consumer credit card market, including a review of the terms of credit card agreements and practices and the impact of the CARD Act on the cost and availability of credit, particularly with respect to non-prime borrowers. This year, the Bureau requests information about how the credit card market is functioning and asked for comment on seven specific topics of interest, as well as any information the public believes relevant to the review of the credit card market.

This letter covers five topics: (I) Access and Availability of Credit Cards, (II) Credit Card Rewards, (III)Competition in the Credit Card Market, (IV) Disclosures and E-SIGN, and (V) Credit Reporting. Pursuant to the Bureau's request, we have listed the relevant questions from the Request for Information in each section.

Download the comment letter to read the full text.