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Reflections on Credit CARD Act Day

posted by Adam Levitin

Today most of the provisions of the Credit CARD Act went into effect.  It's been widely noted in various media outlets.  The CCARD Act will surely cause some changes in the credit card industry's business model.  I think there's scant evidence that its going to cause the total cost of credit to go up, however.  The card industry has long been so clever in its product design that it wouldn't leave any available consumer surplus on the table.  Instead, I think we're going to see reconfigured pricing structures and smaller profit margins for card issuers (meaning greater consumer surplus).  

The CCARD Act's fully effective date is time for some reflection on how financial services reform has progressed.  Two thoughts: 

First, we should recognize that the Credit CARD Act is the only regulation of the financial services industry to occur since the financial crisis.  That's troubling.  There were and continue to be lots of problem practices in the card industry, but the crisis wasn't about credit cards.  Federal regulatory agencies have passed some important regs, but they're playing catch-up for a decade of neglect. 

Second, card issuers are going to engineer around the CCARD Act as much as they possibly can.  How fast will we see those changes?  (Some changes are already emerging, as a CRL study notes).  And how will regulators react?  Will the Fed (and OTS and NCUA) be more aggressive in using their UDAP powers?  Or will they only use them when Congressional action is threatened (as occurred with the CCARD Act)?  In other words, has a new regulatory culture emerged or are the existing consumer protection agencies unable/unwilling to respond to new billing tricks and traps as they appear?  How the agencies respond going forward is another test of whether we can rely on the existing regulatory structure or whether the only way we will get real consumer protection is a stand-alone Consumer Financial Protection Agency. 

Comments

My credit union was trying to sell credit cards today - they were giving 25 reward points if you could tell the teller what your credit card interest rate is. If someone doesn't already have a credit union card, half the interest rate is a pretty good pitch.

God bless you for saying it Hillary. Anyone who can get membership into a Credit Union and chooses to stay in a bank is a fool. There is no other way to put it. An absolute fool.

I have been searching for a website like this in the field I am interested in. I am a big fan. I was thinking about creating my own blog about similar ideas for like-minded people. Some good ideas here. Thanks, I can only hope mine turns out as good as this one
American finance solution

For anyone that is looking, you can go to http://www.creditunion.coop/cu_locator/quickfind.php to find a Credit Union in your community.

If I was a jerk I would give you the link to my site which has the link to Felix Salmon's site. But I'm not a jerk. Felix Salmon has the most recent up-date (as of Feb 24th) on the CFPA legislation. You won't like what you read. No surprises.http://blogs.reuters.com/felix-salmon/2010/02/24/has-corker-killed-the-cfpa/ Join a Credit Union if you can, say a prayer to Jesus for our nation's future and take care peoples.

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