PLA has for many years posted elite academic research questioning the utility of CARD Act disclosures. For example, in 2013 we posted Regulating Consumer Financial Products: Evidence from Credit Cards by Sumit Agarwal from Georgetown University, Souphala Chomsisengphet from the Office of the Comptroller of the Currency, Neale Mahoney from the University of Chicago Booth School of Business and National Bureau of Economic Research, and Johannes Stroebel from New York University, the National Bureau of Economic Research, and the Centre for Economic Policy Research (CEPR). (See the 2014 update here). Similarly, PLA today posts Minimum Payments and Debt Paydown in Consumer Credit Cards, by Benjamin Keys from the Wharton School and Jialan Wang from the Consumer Financial Protection Bureau (now at the University of Illinois). This study concludes that fewer than 1% of consumers viewing the CARD Act-mandated 36-month repayment amount disclosure adopted an alternative monthly payment. We will continue to monitor research in this area and will keep PLA readers apprised of pertinent developments.
Our Payments Team addresses changes and continuities in the payments industry every day—leveraging our many years of industry experience and our presence on both coasts and in China. On paymentlawadvisor, we offer commentary on new developments that seem particularly significant, as well as resources that we believe can be helpful to others who are tasked with anticipating, understanding and addressing these developments.
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