Regulatory Comment on Credit CARD Act Reasonable and Proportional Rule

The Pew Safe Credit Cards Project submitted comments to the Federal Reserve Board in regard to rulemaking under the Credit CARD Act of 2009. These comments focused specifically on the law's requirement that penalty fees and charges must be reasonable and  proportional to related cardholder omissions or violations. In addition to providing data from Pew's research on current use of penalties in the credit card market, Pew made several key recommendations regarding the Board's rulemaking effort.

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