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CUNA joined other organizations to request at least a 60-day extension of the comment deadline for the Consumer Financial Protection Bureau’s proposal on credit card late fees. The CFPB proposed the rule in February with a 60-day comment deadline.
The proposal includes “novel and unanticipated” amendments to Regulation Z, including, for example, a late payment fee cap of 25% of the minimum periodic payment.
“Determining the impact of the proposed amendments to Regulation Z on consumer cardholders using data and models – information lacking from the [proposal] – will require considerable time to attempt to gather and analyze relevant information to respond meaningfully to the proposal. Failure to provide sufficient time for industry to consider the proposed rule’s impact on consumers would result in an incomplete administrative record and arbitrary agency action, and likely would result in unintended consequences, adverse consumer and small business impact, and ultimately create flawed public policy.
The letter adds that this risk is compounded by the fact that the CFPB did not convene a small business review panel, as required by statute.
“A rush to finalize significant changes to a long-standing rule that has endured through CFPB leadership appointed by both political parties, without providing sufficient time for commenters to provide data and other information on consumer and market impacts, would invite scrutiny and the likelihood of future revision, which would not benefit anyone,” the letter reads. “We respectfully request that the CFPB give industry and the public sufficient time to provide data-driven comments that will promote sound and durable policy decisions.”