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#21249 - 06/19/02 06:29 PM Credit Card Review
CalifDreamin Offline
Diamond Poster
CalifDreamin
Joined: Mar 2002
Posts: 2,276
Far from Calif
Does anyone have any checklists that you have developed that you would be willing to share to aid in a credit card review? Thank you!
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Lending Compliance
#21250 - 06/20/02 12:44 PM Re: Credit Card Review
AnonRegulator Offline
Gold Star
AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
Other than our exam procedures, I don't have any other checklists to follow. However, for credit card operations, there is a hot topic called unfair and deceptive practices. There have been a few cases in which credit card banks have been hit with substantial fines due to unfair and deceptive practices. Hopefully, this won't apply to your bank.

If your bank offers a credit card product that, due to fees and other things that are sold to the customer, leaves a very small amount of available credit to the borrow at the inception of the card, be concerned, particularly if the product is geared to sub-prime borrowers under the guise of a credit repair program for them.

Look at the complaints you and your regulator have received about the product. It takes a lot for a customer to complain to either a bank or a regulator, so when we see a lot of complaints, we know there is some problem worth investigating. That could be the method by which those things were sold to the customer. If the scenario involves a subprime product with little initial available credit (like $75 or less) and high pressure telemarketing, you may be at risk for unfair and deceptive practices.

One way to minimize that risk is to make sure that ALL the costs of your credit card product are very conspicuously disclosed. If the initial available credit will be small due to fees, charges or security deposits, be sure that fact (the small available credit) is also conspicuously disclosed to the customer. In other words, tell the customer what you do, and don't just bury it in the fine print. AR.

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