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Monday, July 28, 2014

Has the CFPB Issued Guidance on the Disclosure of Unemployment or Disability Limitations in Debt Protection or Credit Insurance?

By: ABIA Outside Counsel Chrys D. Lemon and Adam D. Maarec, McIntyre & Lemon, PLLC

The Consumer Financial Protection Bureau (CFPB) has issued a series of enforcement actions related to allegedly deceptive marketing of debt protection products in connection with credit cards. The CFPB also issued a bulletin that addresses the marketing of add-on products, including debt protection products and credit insurance in some circumstances. The bulletin states that terms and conditions must be accurately stated, and that “material limitations on eligibility for benefits” should be disclosed.

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