On Sept. 19, 2019, the Consumer Financial Protection Bureau (CFPB) issued its 19th edition of Supervisory Highlights containing key compliance findings from CFPB examinations. One key finding financial institutions should take note of relates to online credit card advertisements. The CFPB found that financial institutions are not complying with Regulation Z when advertising credit cards online. Regulation Z requires credit card advertisements to clearly and conspicuously provide required disclosures if the advertisements contain certain terms, called “triggering terms”. The required disclosures were sometimes available, but only if the consumer clicked on a non-descriptive hyperlink or completed an eight-page application. This is not considered clear and conspicuous. Given the fact, the CFPB has highlighted online credit card advertising as a key compliance finding. You should expect prudential regulators to spend more time examining websites for this issue.
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