WASHINGTON, March 05, 2024–(Company WIRE)–James Mann and David Gossett, expert lawyers and associates at the law business Davis Wright Tremaine, are readily available to discuss with reporters concerning the Shopper Monetary Safety Bureau’s new rule regarding credit card late charges. James and David signify numerous of the leading financial institutions, FinTech providers, and economic services organizations in the nation, and have served these consumers establish and address their most hard regulatory and compliance desires.
James has been advising clientele on determining and addressing their most hard regulatory and compliance challenges due to the fact 2001, when he left the Federal Reserve, obtaining aided compose Regulation P as very well as content amendments to other regulations. David is a major appellate and regulatory litigator who previously served as the first assistant basic counsel for litigation at the CFPB, where he aided stand up the company and set up and ran the appellate and defensive litigation team.
James and David have well prepared the below original commentary, which can be utilized verbatim in coverage of the rule, and they are also out there for interviews.
James Mann, Davis Wright Tremaine:
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The deep slash in the risk-free harbor quantity may perhaps prompt issuers to set their late fees outside the safe harbor. Non-secure harbor late costs may perhaps be double the risk-free harbor sum or a lot more. And they’ll differ from issuer to issuer and around time, complicating consumers’ comparison purchasing.
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The Rule does not only cut the safe and sound harbor amount of money it also denies issuers the proper to thoroughly recuperate their charges by means of late fees exterior the secure harbor. (Specifically, the Rule eradicates issuers’ ideal to get better write-up-cost-off collection expenses. These stand for a real and substantial price for issuers.)
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The Rule encourages issuers to value transparently but also envisions that issuers will raise their APRs. This will make no perception considering the fact that raising the APR to compensate for late-payment expenses alongside with receivables funding charges essentially lessens transparency.
David Gossett, Davis Wright Tremaine:
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In its rush to attain a pre-ordained result, the Bureau ran roughshod over the details and other supplies submitted in reaction to its Notice of Proposed Rulemaking.
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I expect that the courts are likely to review the CFPB’s evaluation below incredibly cautiously, and—especially presented the simple fact that the Supreme Court is at present revisiting how much deference businesses get—may perfectly vacate the agency’s new rule.
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I’ll be shocked if someone does not sue the Bureau above the new rule.
About Davis Wright Tremaine
Davis Wright Tremaine LLP is an AmLaw 100 law agency with a lot more than 600 attorneys representing purchasers dependent through the United States and around the entire world. Study a lot more at www.dwt.com.
Perspective supply version on businesswire.com: https://www.businesswire.com/information/house/20240305012749/en/
Contacts
Mark Fefer
Davis Wright Tremaine LLP
206.757.8583
[email protected]
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