Like many banks, we do not issue our own credit cards. The cards carry our bank name but are issued by another bank. I don't remember the Credit Card Act requiring to disclose the issuing bank. Is this a requirement? What about UDAAP? By excluding the issuing bank's name, including only the issuing bank's mailing address on brochures and applications but using our bank's name, couldn't it be considered unfair or deceptive?

We have the same situation, and the same concerns. I'd be interested in comments.

The Independent Bankers Assn of Texas indicated this may be a UDAAP issue. Ironically, I discovered that out CC issuing bank has changed the disclosures on their application to reflect the name of their bank and the fact that their bank is the issuing bank for the card. Sounds to me like the UDAAP message is getting around.