Compliance Blog

Wrtiten by Steve Van Beek

Well, the CFPB wasn't lying when it stated its initial focus would be on mortgages, credit cards and student loans.  We now have "Know Before You Owe" projects for each one.  

• Know Before You Owe: Mortgage Loans

• Know Before You Owe: Student Loans

• Know Before You Owe: Credit Cards

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Yesterday, the CFPB announced their first steps toward clarifying and condensing credit card agreements.

• Press Release

• Prototype Credit Card Agreement

• Listing of Definitions for Prototype Agreement

The announcement also came with a pair of blog posts from the CFPB.  

• Shopping for a Credit Card

• Making Credit Card Agreements Understandable

Similar to the other Know Before You Owe projects, the CFPB is actively soliciting feedback on their prototype.  Importantly, this is not a proposed rule.  However, it is the CFPB's first steps toward collecting information and attempting to clarify credit cards for consumers.  (I'm sure many compliance officers are wanting some clarification as well - and not the kind of "clarifications" the Fed dropped on everyone earlier in 2011).

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If your credit union offers credit cards, be sure to review the prototype.  It might be a good idea to have preliminary discussions with your forms provider as well.  Would they be able to make these changes?  How long would that take?  At what cost?   

This also might be a good time to put together a summary of the headaches during the last round of "tweaks" to credit card disclosures.  Detailed, specific information on the timeframe, steps and costs to comply with the most recent changes to credit cards would be very useful during the prototype stage and especially during any future proposed rulemakings.