The ABA has submitted a letter to the CFPB applauding its proposal to reconsider the Federal Reserve Board’s interpretation of the Truth in Lending Act (TILA) requirement that lenders consider the ability of the borrower to make payments before opening a credit card account.
The CFPB’s proposal amends the implementing regulation, Regulation Z, to eliminate the current requirement that those 21 or older demonstrate an “independent” ability to obtain a credit card.
ABA supports the proposed amendments as they will help to ensure that stay-at-home spouses and partners have access to credit cards in their own names, as well as the ability to build their credit history, without having to rely on the approval or control of their spouse or partner.
In regards to the final rule, ABA has requested the CFPB provide additional clarification about reliance on income and asset information requested with the application; additional examples of income qualifiers; and the inclusion of other types of income in examples of income.
Read the full letter.