Credit Card Agreements

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?

You do not want to be providing all of the consumer protections to your commercial credit card customers - do you?

No. I was fairly certain there should be two. I just wanted to confirm that. Thank you rclarey.

Is there any way that you can provide us with a sample of your credit card agreements? Thank you.

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?

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 § 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.