Regulatory Update

The Office of the Comptroller of the Currency (OCC) published guidance for national banks in early September on three specific credit card practices it "regards as unacceptable because they may constitute unfair or deceptive acts or practices, or could otherwise expose a bank to compliance and reputation risk." The three practices are: increasing the cost of credit to an individual cardholder without adequate disclosure of the circumstances that would trigger an increase or the creditor’s right

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