Rules proposed for credit card fee disclosures

Credit card reform: The fine print of proposed changes to Regulation Z

When it comes to disclosing fees, the difference between the old and the proposed approaches is stark. Under the current Regulation Z , fees are grouped in one small box of the larger disclosure table, with one exception, one that illustrates the problem with the old fee disclosure table.

45 days' notice
Fixed rates
APR disclosures

Fee disclosures
Account opening disclosures
Periodic statement disclosures
Changes in credit card terms
Minimum payments
Subprime credit cards

"Annual fees" are disclosed in one section followed by the "Minimum finance charge" in another, then four other fees are crowded together in a lone section at the bottom of the disclosure table.

The Federal Reserve's proposed fee disclosure table puts every fee in its own table, one with a large banner. Immediately below the banner, are separate boxes, each with a bold-faced label: Annual fee, Transaction fees, Penalty fees and Other fees. Further, the proposed fee disclosure contains some critical information that current disclosures may bury or omit.

Bank of America notes, "Grouping of fees under one heading follows a certain logic, but it will not always serve the consumer ... " Read more (Page 13)

The chairwoman of the New York State Consumer Protection Board says the amendment doesn't go far enough: "The disclosure of a fee in a table does not necessarily make it less deceptive or unfair ... " Read more (Page 2)

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Updated: 11-17-2017