Facts Matter*


*Over the past year, the CFPB has consistently published reports, studies, and blogs misrepresenting publicly available data to support their politically motivated policy agenda. In response, CBA launched “Facts Matter” using the Bureau’s own data and analysis to rebut their claims.

If you take the time for context and look at late fees as a share of balances, late fees have remained relatively constant since 2015

According to the CARD Act Report, market share for the next 20 issuers grew by the same percentage in that time frame.

Facts matter when policymakers write regulations.

Since the beginning of the Biden Administration, the Consumer Financial Protection Bureau (CFPB) has pushed forward major, industry-reshaping policy changes by misleading press releases.

As the agency’s own data show, these portrayals are often riddled with contradictions and inconsistencies.

The CARD Act Report

FACTS MATTER ON CREDIT CARDS

A four-part series contrasting the CFPB’s CARD Act Report press release against reality, primarily using the data from the CFPB’s own research.


CFPB’s Credit Card Rewards Report Misses the Forest for the Trees

A new report from CFPB once again mischaracterizes the highly competitive credit card market, specifically rewards programs. We call out these distortions, showing how competition and consumer choice actually benefit consumers with diverse and valuable rewards options.

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Clearing the Air on Credit Card Rewards

We dive into the Federal Reserve's recent credit card working paper, to separate the facts from the fiction and emphasize a key finding of the author’s research: the vast majority of money that’s paid into rewards cards comes from high-income consumers – with the benefits of rewards cards spread out more evenly across cardholders of all incomes.

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Checking the Math Behind the CFPB’s Comparison of Credit Card Interest Rates Between Large and Small Issuers

The CFPB’s recent comparison of credit card interest rates between large and small issuers is fundamentally flawed. We highlight errors in their analysis, revealing the CFPB ignored key data and misrepresented the actual rate differences – especially for subprime cardholders.

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FACTS MATTER ON OVERDRAFT AND NSF


In NSF Fee Press Release, CFPB Misrepresents Bank Advancements that Save Consumers Billions

In this installment of Facts Matter, we highlight how most major banks have already removed NSF fees without regulatory mandates, saving consumers billions. The CFPB’s reliance on outdated data to justify new rules is a disservice to consumers who are already benefiting from these changes.

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CBA Statement On CFPB’s Misleading Overdraft Press Release

The CFPB misleadings with its release on overdraft fees, excluding the 26 million "credit invisibles" who benefit from these services. We spotlight how overdraft services are essential for consumers without access to traditional credit products, serving as a crucial safety net. By ignoring these consumers, the CFPB’s portrayal is flawed, focusing on outdated data and missing the true value of overdraft protections

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FACTS MATTER ON SCAMS AND FRAUD


CFPB Attempts to Use a Blog Post to Rewrite a 46-year-old Payments Statute

In a recent blog post, the CFPB highlighted an amicus brief in New York v. Citibank, N.A., regarding the handling of consumer wire transfers that affected consumer accounts. Remarkably, the CFPB asks the court to rewrite the plain language of the Electronic Fund Transfer Act, and effectively reverse decades of settled law. By issuing the blog post, the CFPB presumably would apply this new “rule” to the industry at large. 

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Further Reading

RealClearMarkets

The CFPB's Flawed Credit Card Rate Analysis

Todd Zywicki & Julian Morris