On May 1, BPI submitted a comment letter in response to the Consumer Financial Protection Bureau’s (CFPB) request for information in connection with the CARD Act’s requirement that it conduct biennial reviews of the consumer credit card market. The letter notes that the linear analysis required under the CARD Act and Regulation Z of a borrower’s ability-to-repay prevents issuers from accounting for other factors that may otherwise indicate creditworthiness, and thus limits the ability to increase comprehensive access to credit for non-prime and higher-risk borrowers. Further, the letter encourages modifications to Regulation Z to maximize the efficiencies of online servicing methods. The letter similarly urges for modernization of the Act and Regulation Z’s disclosure framework, so as to provide a flexible approach for delivering mandated disclosures that accounts for technological changes and the ubiquity of digital channels.
Bank Activities and Structure
BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Digital Assets, Financial Technology and Inclusion
BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Digital Assets, Financial Technology and Inclusion
Consumer Affairs
Limiting Medical Payment Options Won’t Deter Costs but Will Reduce Access to Services
Limiting Medical Payment Options Won’t Deter Costs but Will Reduce Access to Services
Bank Capital and Stress Testing
BPI and ABA to Regulators: Capital Increases, Court Uncertainty Could Complicate Banks’ CRA Programs
BPI and ABA to Regulators: Capital Increases, Court Uncertainty Could Complicate Banks’ CRA Programs
