It has been more than four years since the Credit CARD Act was passed by Congress and more than three years since the compliance dates set by the Federal Reserve Board (many compliance professionals may still be haunted by the date Feb. 22, 2010). While it would seem like credit card compliance issues are in the rearview mirror, now is the perfect time for credit unions to review their procedures to ensure they remain compliant.

Now that the Consumer Financial Protection Bureau has met its Dodd-Frank mandates, its attorneys are freed-up to review other areas of concern—including credit cards. The CFPB has repeatedly stated it will use consumer complaints as a prime indicator of where to place its resources. Not surprisingly, credit cards are the number two category of complaint at 21% (edged out only by mortgages at 48%). And, from a global perspective, the CFPB wants to protect as many consumers as possible. By focusing on mortgages and credit cards (not to mention student loans), the CFPB is certainly casting a wide net.

Two reports from the CFPB provide valuable insight into the future focus on credit cards. First, the CFPB’s Fall 2012 Supervisory Highlights identified areas of concern the CFPB found during examinations of the largest depository institutions. Most credit unions are aware of the prominent fines to large banks for unfair or deceptive acts or practices related to credit card add-on products. And, that was not a one-time event, as the CFPB has continued to analyze issues related to credit card add-on products—including a recent settlement with Chase Bank and ongoing talks with Bank of America. While credit unions may not have had the same types of credit card add-on products, the compliance (and reputation) risks are definitely ratcheted up in the credit card area.

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