Americans for Financial Reform Education Fund, Consumer Federation of America, and the National Consumer Law Center submitted the following comments in response to the CFPB’s Advance Notice of Proposed Rulemaking on Credit CARD Late Fees and Late Payments. We thank the CFPB for taking the initiative to re-examine whether the Regulation Z provisions governing credit card late fees still produces safe harbors and late fees that are “reasonable and proportional” to the costs incurred by the credit card issuer from late payments.