CFPB Answers Our Letter About Possible CARD Act Violations at Schools


We support reforms to the financial marketplace that protect consumers from unscrupulous banks and lenders.

By Consumers Union on Monday, March 16th, 2015

We recently told you about our investigation into whether colleges and universities with credit card marketing agreements were making their agreements available to the public.  Using information from the CFPB’s college credit card database, we contacted 10 schools with the largest active account volume that did not post their agreements or offer guidance for how to get them online. None of the schools provided us with any information or copies of their college credit card agreements.

We reported our findings to the CFPB, letting them know that schools may be violating the law and asking them to investigate further.  We think the public has a right to know whether these contracts are designed to give students and alumni a good deal, or simply to help the schools’ bottom lines.

Shortly after sending our letter to the CFPB, we received a letter from Yale University telling us they have posted their alumni credit card agreement online.  We were also notified that University of Pittsburgh recently ended its own agreement.

At the end of last week we received a response from the CFPB, thanking us for our inquiry and promising to monitor the market further.  The letter notes that: “While institutions of higher education are not specifically required to post the agreement online, it is a simple, clear way to meet the disclosure requirement of the CARD Act….Given the low burden to potential requestors and the institution of higher education, it is peculiar that not all institutions have chosen this method of disclosure.”

We couldn’t agree more.   The 8 remaining schools on our list have yet to respond – do they still have agreements in effect?  If so, will they post them online?  We urge them to take the appropriate action.

Meanwhile, we think the CFPB should go one step further and amend their CARD Act guidance, to make it clear that schools must post their credit card agreements online so they are truly public.

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