Comment Call: Proposal to Amend Reg Z's Credit Card Fee Limitation
Proposal to Amend Reg Z's Credit Card Fee Limitation
The Consumer Financial Protection Bureau has issued a proposed rule to amend § 1026 of Regulation Z regarding credit card fee limitations.
Currently, § 1026.52(a) limits the total amount of fees that can be charged on a credit card account prior to account opening and during the first year after account opening. However, this limitation has not yet become effective as a result of pending litigation on the issue.
The proposed rule would amend § 1026.52(a) to provide that the limitation on credit card fees applies only during the first year after account opening.
We believe the proposal is positive and will benefit some credit card issuers. However, we do not believe it will have a major impact on credit union issuers directly, based on the fees they typically charge on members’ credit card accounts.
Click here for CUNA's Regulatory Comment Call on the CFPB's proposed amendment to Reg Z regarding credit card fee limitations, and contact Luke Martone with any questions.
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