Letter to CFPB on Consumer Credit Card Market

ABA submitted comments to the request for information of the Bureau of 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). Section 502(a) of that act requires the Bureau to conduct a review of the consumer credit card market every two years. The Bureau requests information about how the credit card market is functioning and asks 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.

ABA comments focus on: changes in the cost and availability of consumer credit cards since the Bureau’s last report in 2017; the need to improve the debt collection rules; credit card product innovation, including the use of artificial intelligence and regulations that inhibit advancement in customer and card issuer communications.