On September 3, 2014, the CFPB issued a bulletin warning credit card issuers about marketing practices related to promotional interest offers. The bulletin focuses on consumer acceptance of a promotional offer that causes the consumer to lose a grace period on new purchases if the consumer does not pay the entire statement balance by the payment due date. The bulletin states that credit card issuers who fail to adequately "alert consumers" in marketing materials about the relationship between promotional APR offers and a grace period may be engaging in "abusive conduct." For our client alert on this topic, click here.
Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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