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#2251540 - 03/31/21 02:07 PM Credit Card Agreements
City Girl Offline
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Joined: Sep 2005
Posts: 141
Midwest
For those of you that offer Credit Cards to consumer and commercial customers, do you have a consumer credit card agreement and a commercial credit card agreement? Or, do you just have one agreement?

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#2251544 - 03/31/21 02:28 PM Re: Credit Card Agreements City Girl
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 76,947
Galveston, TX
You do not want to be providing all of the consumer protections to your commercial credit card customers - do you?
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#2251568 - 03/31/21 04:10 PM Re: Credit Card Agreements City Girl
City Girl Offline
100 Club
Joined: Sep 2005
Posts: 141
Midwest
No. I was fairly certain there should be two. I just wanted to confirm that. Thank you rclarey.

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#2252201 - 04/12/21 02:36 PM Re: Credit Card Agreements City Girl
Bruce Gollop Offline
New Poster
Joined: Apr 2021
Posts: 10
Is there any way that you can provide us with a sample of your credit card agreements? Thank you.

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#2259072 - 08/31/21 11:12 PM Re: Credit Card Agreements City Girl
Mel in WA Offline
Diamond Poster
Joined: Mar 2013
Posts: 1,113
Question related to credit card agreements. If you outsource your credit cards (underwriting, service, etc.) to a third party vendor, is the bank responsible for posting the credit card agreement on the bank's website, per 1026.58?

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#2259103 - 09/01/21 05:51 PM Re: Credit Card Agreements City Girl
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,289
Cape Cod
The CFPB posting is all about the card issuer and the credit card agreement. The card issuer is the entity to which the consumer is legally obligated under the terms of the agreement.

If your bank is the issuer, you have the responsibility of compliance with ยง 1026.58. You can outsource to a third party the submission of the agreement to the CFPB, but you can't outsource the responsibility for filing it.
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