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A national bank reached an agreement with the Consumer Financial Protection Bureau ("CFPB") to pay $335 million in restitution to customers affected by alleged failures to appropriately adjust annual credit card interest rates.
As explained in the Consent Order, the CFPB determined that the bank violated the Truth in Lending Act by failing to correctly calculate customers' annual percentage rates ("APRs"). The CFPB concluded that the bank did not properly assess eligibility for an APR reduction in various ways (e.g., it disqualified customers based on their FICO scores). The CFPB further found that the bank did not have adequate written policies and procedures in place for APR reevaluations.
As part of the Consent Order, the bank will be required to submit to the CFPB a written plan for remedial efforts. The CFPB noted that the bank self-reported the violations and self-initiated remediation to customers. As a result, the CFPB elected not to issue a civil monetary penalty.
The bank agreed to the Consent Order without admitting or denying the CFPB's findings.
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