Kristen Larson on Late Fees

Operational impacts of the new CFPB Credit Card Late Fee Rule

On March 5, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued its final credit card late fee rule (the “Final Rule”), which, amongst other things, significantly reduces the late fee safe harbor cap for issuers...more

3/21/2024 / Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Credit Cards , Final Rules , Financial Institutions , Financial Regulatory Reform , Financial Services Industry , Late Fees , Preliminary Injunctions , Proposed Rules , Regulation Z , Regulatory Agenda , Safe Harbors

CFPB notifies Texas federal court of intention to move to transfer case challenging final credit card late fee rule; plaintiffs...

This week, the CFPB filed a notice with the Texas federal district court stating that it intends to move to transfer the lawsuit challenging the CFPB’s final credit card late fee rule (Rule). The notice was filed pursuant to...more

3/21/2024 / Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Consumer Lenders , Credit Cards , Debt Collection , Final Rules , Financial Institutions , Financial Regulatory Reform , Financial Services Industry , Late Fees , Motion to Transfer , Preliminary Injunctions , Regulatory Agenda

Texas federal judge hearing trade group lawsuit challenging CFPB final credit card late fee rule questions whether venue is proper...

The federal district court judge to whom the lawsuit challenging the CFPB’s final credit card late fee rule (Rule) was reassigned entered an order this week questioning whether the Fort Worth Division of the Northern District...more

3/20/2024 / Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Consumer Lenders , Credit Cards , Debt Collection , Final Rules , Financial Institutions , Financial Regulatory Reform , Financial Services Industry , Late Fees , Motion to Transfer , Preliminary Injunctions , Regulatory Agenda , Truth in Lending Act (TILA)

CFPB and plaintiffs fully brief motion for preliminary injunction in trade group lawsuit regarding final credit card late fee rule

The Consumer Financial Protection Bureau (“CFPB”) filed an opposition brief (the “Opposition”) on Tuesday in response to a request by plaintiff trade groups to enjoin the CFPB’s final credit card late fee rule (the “Final...more

3/18/2024 / Administrative Procedure Act , CARD Act , Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Consumer Lenders , Credit Cards , Debt Collection , Federal Student Loans , Final Rules , Financial Institutions , Financial Regulatory Reform , Financial Services Industry , Health and Essential Rights (HERO) Act , Late Fees , Motion To Enjoin , Preliminary Injunctions , Truth in Lending Act (TILA)

Trade groups file lawsuit in Texas federal court challenging CFPB final credit card late fee rule and ask for preliminary...

Just two days after the CFPB issued its final credit card late fee rule (Rule) last week, a lawsuit was filed in a Texas federal district court seeking to invalidate the Rule. The plaintiffs in the lawsuit are the Chamber of...more

3/14/2024 / Administrative Procedure Act , CARD Act , Consumer Financial Protection Bureau (CFPB) , Consumer Financial Protection Bureau v Community Financial Services Association of America Ltd , Credit Cards , Dodd-Frank , Final Rules , Financial Services Industry , Late Fees , Oral Argument , Preliminary Injunctions , Safe Harbors , SCOTUS , Truth in Lending Act (TILA)

The Once and Future Rule: How the CFPB’s Credit Card Late Fee Rule Compares to Regulation Z and the Previously Proposed Rule

On March 5, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued its final credit card late fee rule (the “Final Rule”). The timing for publication of the final rule was widely perceived as coordinated with the...more

3/12/2024 / Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Credit Cards , Financial Institutions , Financial Regulatory Reform , Financial Services Industry , Late Fees , Notice of Proposed Rulemaking (NOPR) , NPRM , Preliminary Injunctions , Proposed Rules , Regulation Z , Regulatory Agenda

CFPB finalizes credit late fee rule and sets $8 large issuer safe harbor

Yesterday, the CFPB issued its final credit card late fee rule. As we expected, the final rule was released prior to President Biden’s March 7th State of the Union address. The final rule reduces the late fee safe harbor...more

3/6/2024 / Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Credit Cards , Final Rules , Financial Services Industry , Late Fees

CBA “checks the math” on recent CFPB credit card report finding large bank issuers charge higher interest rates than smaller...

After targeting credit card late fees in its proposed rule, the CFPB has set its sights on further attacking credit card pricing through interest rates. The CFPB published a blog late last month stating that credit card...more

3/5/2024 / Annual Percentage Rate (APR) , Banks , Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Credit Cards , Financial Regulatory Reform , Financial Services Industry , Interest Rates , Late Fees , Proposed Rules , Regulatory Agenda

New CFPB credit card report finds large bank issuers are charging higher interest rates than smaller issuers

In a new data spotlight issued last week, the Consumer Financial Protection Bureau (“CFPB”) found that interest rates charged on credit cards issued by large banks are higher than interest rates charged on credit cards issued...more

2/20/2024 / Banks , Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Credit Cards , Financial Regulatory Reform , Financial Services Industry , Interest Rates , Late Fees , Proposed Rules , Regulatory Agenda

CFPB proposes rule to ban “rarely charged” NSF fees for declined transactions based on wildly expansive view of “abusive” prong

On January 24, 2024, a week after issuing its proposed rulemaking for overdraft services, the Consumer Financial Protection Bureau (“CFPB”) issued its proposed rulemaking on non-sufficient funds (NSF) fees....more

1/29/2024 / ATMs , Consumer Financial Products , Consumer Financial Protection Act (CFPA) , Consumer Financial Protection Bureau (CFPB) , Consumer Protection Act , Dodd-Frank , Financial Institutions , Financial Regulatory Reform , Financial Services Industry , Insufficient Funds , Late Fees , Overdraft Fees , Proposed Rules , Regulatory Agenda , Rulemaking Process

CFPB’s credit card late fee final rule and overdraft and NSF fee proposed rulemaking expected prior to President Biden’s March 7th...

Speaker of the House Mike Johnson (R-LA) has invited President Joe Biden to give his State of the Union address to a Joint Session of Congress on Thursday, March 7, 2024. The invitation was immediately accepted by President...more

1/17/2024 / Biden Administration , Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Credit Cards , Financial Regulatory Reform , Financial Services Committee , Financial Services Industry , Insufficient Funds , Late Fees , Overdraft Fees , Proposed Rules , Regulatory Agenda , Rulemaking Process , State of the Union

Kristen Larson

Ballard Spahr LLP

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