April 24, 2023 — Comments

The National Consumer Law Center (on behalf of our low-income clients) and Consumer Federation of America submitted comments to the CFPB’s 2023 Request for Information (RFI) Regarding the Consumer Credit Card Market. These comments focus on the following topics:

A. Deferred Interest. It is way past time for the CFPB to eliminate deferred interest, which harms millions of Americans every year.

B. Medical credit cards. The CFPB should specifically study medical credit cards and adopt reforms to prevent deceptive, unfair, and abusive practices when these cards are offered by healthcare providers.

C. Online-only statements and disclosures. The CFPB should preserve the ability of consumers to receive paper disclosures and statements, should stop deceptive methods and dark patterns used to push people unknowingly into giving up their paper statements, and should require issuers to provide easy-to-use methods to switch back to paper. The CFPB should also develop versions of statements and disclosures that are mobile friendly.

D. Military Lending Act issues. According to the Department of Defense’s review of the Military Lending Act (MLA), the MLA is working as intended. However, the CFPB should conduct its own detailed research into the impact of the MLA and Servicemembers Civil Relief Act’s coverage of credit cards on servicemembers, and not rely on flawed outside research that portrays such impact in a negative light.