Credit and Debit Cards
Our Credit and Debit Cards practice area focuses on federal regulation of credit and debit cards and compliance with card association rules. We advise clients with questions concerning:
- Credit Card Accountability Responsibility and Disclosure Act of 2009 and implementing regulations
- Electronic Fund Transfer Act and Regulation E
- Fair Credit Billing Act and implementing regulations
- Truth in Lending Act and implementing regulations, and comparable state laws and regulations
- Other laws and card association rules applicable to credit cards, debit cards, payroll cards, prepaid value, and gift cards
We also counsel clients on state laws affecting credit and debit card programs, including issues related to exportation of interest rates and fees, and compliance with and (where appropriate) potential preemption of state and local laws.
We draft and review consumer-facing documents related to card programs, including advertising, card agreements, change in terms notices, error resolution and account correction matters, periodic statements and other disclosures and communications (including servicing communications) related to card accounts.
We have helped financial institutions with development of compliance systems, programs and testing geared toward their consumer card programs.
Our clients include many large banks and primary card issuers in the United States. In addition, we represent retailers in connection with private label credit card accounts.