comment letter

Joint Trades Request for Extension of the Comment Period for NPRM on Credit Card Late Fees


Dear Director Chopra:

The American Bankers Association, Bank Policy Institute, Consumer Bankers Association, Credit Union National Association, Independent Community Bankers of America, National Association of Federally-Insured Credit Unions, and National Bankers Association, representing banks and credit unions across the regulated financial system, write with respect to the comment deadline for the Consumer Financial Protection Bureau’s (“CFPB”) notice of proposed rulemaking regarding Credit Card Penalty Fees (Regulation Z) (“NPRM”). For the reasons stated below, we respectfully request a 60-day extension of the current comment period for the NPRM, to the later of June 3, 2023, or 90 days after the date of publication in the Federal Register.

The Regulation Z penalty fee provisions have not been substantively amended since 2010, when the Board of Governors of the Federal Reserve System promulgated rules implementing the Credit Card Accountability Responsibility and Disclosure Act of 2009. The NPRM proposes, and requests comment on, novel and unanticipated amendments to Regulation Z, including, for example, a late payment fee cap of 25 percent of the minimum periodic payment.


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