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The Consumer Financial Protection Bureau (CFPB) has published its seventh biennial review of the consumer credit card market, as required under the Credit Card Accountability Responsibility and Disclosure (CARD) Act of 2009. The report examines how credit cards are used, how issuers operate, and how the market has evolved, drawing on data through 2024.

The Consumer and Governmental Affairs Bureau (“CBG”) has extended, to January 31, 2027, the effective date of the Federal Communications Commission’s (“FCC”) Telephone Consumer Protection Act (“TCPA”) “global revocation” rule.[i]

As previously reported, in October 2023 the CFPB and DOJ issued a joint statement regarding “the potential civil rights implications of a creditor’s consideration of an individual’s immigration status under the Equal Credit Opportunity Act (ECOA).”

On December 23, the CFPB issued an advisory opinion in the Federal Register clarifying the regulatory treatment of earned wage access (EWA) products under Regulation Z, as implemented by TILA. The advisory opinion stated that certain EWA products, referred to as “Covered EWA,” do not constitute credit under Regulation Z, provided they meet four key criteria: (i) advances are limited to wages already earned and verified by payroll records; (ii) payment occurs exclusively through the employer’s payroll process instead of direct account withdrawals; (iii) providers give clear notice that they will not pursue debt collection, credit reporting, or seek payment from personal accounts if payroll deductions are insufficient; and (iv) providers do not assess individual workers’ creditworthiness. The CFPB emphasized that these products function more like early wage payments rather than extensions of credit, as workers are simply accessing funds they have already earned.

On December 23, the CFPB released its annual fair lending report, which reviews the agency’s enforcement and supervision activities for 2024 and described a significant policy shift in fair lending oversight since the close of the reporting period, reflecting changes implemented under the current administration.