CFPB Releases Latest RFI to Evaluate the Consumer Credit Card Market

3/20/2017 8:00 AM

As part of its third CARD Act review, the CFPB seeks comments on changes to debt collection practices in the consumer credit card market, among other topics.


The Consumer Financial Protection Bureau has published a Request for Information (RFI) on the consumer credit card market as part of its required review under the Credit Card Accountability, Responsibility, and Disclosure (CARD) Act. 

Under the CARD Act, the CFPB is required to conduct a review of the consumer credit market every two years to examine how the credit card market is functioning and the impact of credit card protections on consumers and issuers. The first review was published in October 2013 and the second was published in December 2015.

The latest RFI, which was published in the Federal Register on March 10, requests information from the public about how the credit card market is functioning overall as well as on input related to eight specific topics, including an update on debt collection-related changes

“The Bureau wants to be alerted to and understand the information that consumers, credit card issuers, consumer groups, and others believe is most relevant to the Bureau’s review of the credit card market, so this list of subjects should not be viewed as exhaustive,” the notice states. “Commenters are encouraged to address any other aspects of the consumer credit card market that they consider would be of interest or concern to the Bureau.”

Specific to debt collection, the CFPB states that it previously examined the policies and practices of consumer credit card issuers collections and debt sales operations during its last review.  As a result, the CFPB is now seeking comment on:

  • “What, if any, changes have been made in such policies and practices since the last review?”
  • “If they have changed, what drove the applicable changes?”
  • “What associated market metrics have changed as a result, and how did such changes occur?”
  • “How have market metrics changes in other significant ways, and if so, how and why?”

As context, during the CFPB’s previous review of the credit card market in 2015, that RFI included four questions specifically geared towards debt collection, ACA International previously reported.

In response, after soliciting information from its members that collect credit card debt, ACA submitted comments in June 2015 to educate the CFPB on the significant efforts and resources expended by debt collectors to ensure that credit card debt is lawfully recovered.

In the comments, ACA explained how its members who engage in collecting credit card debt are dedicated to fair and accurate standards, rigorous compliance management systems and oversight, and responsible financial management assistance.  ACA emphasized that like all legitimate credit and collection professionals, ACA members operating in the credit card space play a key role in helping consumers fulfill their financial goals and responsibilities while maintaining the facilitation of the credit market. 

In addition to the debt collection questions, some of the other topics for comment in the latest RFI include:

  • The terms of credit card agreements and the practices of credit card issuers.
  • The effectiveness of disclosure of terms, fees, and other expenses of credit card plans.
  • The adequacy of protections against unfair or deceptive acts or practices or unlawful discrimination relating to credit card plans.
  • The cost and availability of consumer credit cards, the use of risk-based pricing for consumer credit cards, and consumer credit card product innovation.

ACA is currently analyzing the latest RFI. Comments to the CFPB are due June 8, 2017.

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