Has The CFPB's Final Credit Card Late Fees Rule Dealt Cardholders A Winning Or Losing Hand?

On March 5, 2024, the Consumer Financial Protection Bureau issued its final credit card late fees rule which lowers the safe harbor late fee amount that can be charged by issuers other than “smaller card issuers” to $8. While the drastically reduced safe harbor amount has garnered the most attention, the final rule includes other significant changes that merit attention by both smaller and large card issuers. We would like to welcome back to our panel, Andrew Nigrinis, our guest speaker from Legal Economics LLC.

Our discussion topics will include:

1. How the final rule differs from the proposed rule and the existing rule
2. Who is a “smaller card issuer” under the final rule
3. Changes impacting issuers other than smaller card issuers
4. Changes impacting smaller card issuers
5. Changes impacting all card issuers
6. Operational implications of the final rule for card issuers
7. Impact on card issuers (including regulatory considerations in mitigating lost late fee revenue) and existing and potential cardholders
8. Lawsuit challenging the rule filed in Federal District Court in Texas and possible Congressional Review Act Challenge