The CFPB has revised section 1026.52(a) of Regulation Z that addresses the limitation on fees that can be assessed on new credit card accounts.
Previously, the CFPB had interpreted section 1026.52(a) to mean that fees assessed either prior to or during the first year after the credit card account is opened to be limited to no more than 25% of the amount of the credit line in effect when the account is opened. As the result of litigation, the CFPB has modified its interpretation to state that the 25% limit applies only to fees assessed during the first year after the account is opened and not to fees that are assessed before the account is opened. For example, an application fee charged before the account is opened would not be part of the 25% limitation calculation.
The new rule is effective upon publication in the Federal Register. For more information, see the full text of the final rule here.
