b'Credit/Debit/Prepaid CardsCREDIT CARDS During 2019, Goodwin tracked 3 enforcement actions related to credit and debit cards, a significant decrease from the 8 such actions Goodwin tracked in 2018. The 3 actions resulted in just $15 million in combined consumer relief and civil penalties. Though that number is a small fraction of the $963 million obtained as a result of card-related enforcement actions last year, the majority of funds recovered last year were attributable to a single $575 million settlement between state attorneys general and Wells AUTO LOANSCONSUMER FINANCIAL &TELEPHONE CONSUMER Fargo. PROTECTION BUREAU PROTECTION ACTThat federal agencies brought few enforcement actions this year is no surprise. Last year, we predicted that strong resistance by Congress and the White House to the CFPB regulating credit and prepaid cards would cause the Bureau to be particularly reluctant to act in this area. Perhaps more surprising is that other federal agencies and state agencies have shown no desire to use public enforcement to police credit, debit, or prepaid cards. KEY TRENDS upgrade, which was in fact not the case. Consumer MORTGAGESTUDENT LENDINGfinance companies involved in the card industry should DEBT COLLECTION In September, the CFPB released its Summer 2019 edi-tion of Supervisory Highlights. That issue included thepay particular attention to ensuring compliance in these agencys most recent examination findings concerningfour areas in 2020.credit card account management issues. The CFPBSince 2013, the CFPB has issued biennial reports to highlighted four different aspects of noncomplianceCongress regarding the consumer credit card market. it discovered during the course of its examinations: (1)In August, the CFPB issued its fourth Consumer Credit companies failed to provide clear and conspicuousCard Market Report on the state of the credit card mar-disclosures required by Regulation Z when using termsket for the period 2017-2018. The 2019 Report details in online advertisements that triggered disclosurefindings regarding the cost and availability of credit to requirements; (2) companies violated Regulation Zconsumers and emphasizes the increasing difficulty of FEDERAL COURTS OFdemonstrating whether the Credit Card Accountability by offsetting consumers credit card debt against the PAYDAY LENDING APPEALS DATA SECURITYResponsibility and Disclosure Acts (CARD Act) require-consumers funds on deposit with the issuers withoutments are having any specific effects on the market-consumers or intent to grant a security interest in thoseplace. Key findings from the 2019 Report include:(1) the funds; (3) companies violated the CFPA by sendingtotal outstanding credit card balances have continued collection letters threatening to repossess consumersto grow, and at year-end 2018 were only nominally automobiles or foreclose on their homes when theabove pre-Financial Crisis levels; (2) the total cost of companies did not hold a security interest in those ve- credit on revolving accounts increased to the highest hicles or homes; and (4) companies falsely representedoverall level observed by the CFPB; (3) most measures to consumers that secured credit cards would automat- of credit card availability have remained stable or ically be upgraded to unsecured cards on a specificdecreased slightly since 2017; (4) credit card spending timeframe if the card accounts were maintained invia rewards cards has continued to increase over the good standing, and that secured credit cards subjectpast few years; and (5) most basic account servicing to an annual fee would be periodically reviewed for 16 17'