Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 3210 Credit Cards & Credit Reporting In 2015, Goodwin tracked over a dozen enforcement actions against credit card providers, vendors, and national banks, and against credit reporting agencies. The CFPB and state attorneys general brought nearly all of the enforcement actions, but the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) also were active. The enforcement agencies advanced matters using the Fair Credit Reporting Act (FCRA), TILA, and the Unfair, Deceptive, Abusive Acts or Practices (UDAAP) provision of the CFPA to collect civil monetary penalties and consumer relief in excess of $764 million. The enforcement actions focused mostly on misleading and improper offering and sale of credit card add-on products, and the failure for reporting agencies to accurately report credit. Goodwin also covered multiple litigation risks for credit card providers, including increased add-on product litigation, challenges to national bank preemption, borrower lawsuits related to excessive fees, new borrower privacy requirements for credit card issuers, and the CFPB’s forthcoming final pre-paid card rules.