Credit Union National Association
CFPBRulemakingCFPB-2023-0010

Credit Card Penalty Fees (Regulation Z)

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Last modified
Aug 26, 2024
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closed 1182d ago
Credit Union National Association filings
1

Activity

Credit Union National Association filed 1 comment on this docket between May 4, 2023 and May 4, 2023. 35 other organizations filed here. The comment window closed 1182d ago.

What Credit Union National Association filed (1)

May 4, 2023· Comment from Credit Union National Association· CFPB-2023-0010-0211

Attached please find CUNA's comment letter and a supplementary independent economic analysis.

Abstract

The Consumer Financial Protection Bureau (Bureau) proposes to amend Regulation Z, which implements the Truth in Lending Act (TILA), to better ensure that the late fees charged on credit card accounts are “reasonable and proportional” to the late payment as required under TILA. The proposal would adjust the safe harbor dollar amount for late fees to $8 and eliminate a higher safe harbor dollar amount for late fees for subsequent violations of the same type; provide that the current provision that provides for annual inflation adjustments for the safe harbor dollar amounts would not apply to the late fee safe harbor amount; and provide that late fee amounts must not exceed 25 percent of the required payment. For more information about commenting on CFPB’s Notices, please visit us at: https://www.consumerfinance.gov/rules-policy/notice-opportunities-comment/commenting-on-notices/

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