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.
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