On December 10th, the Consumer Financial Protection Bureau (CFPB) entered into a consent order with CareCredit LLC. CareCredit agreed to refund up to $34.1 million to borrowers who were allegedly subject to deceptive credit card enrollment practices.
Prompted by consumer complaints, the CFPB’s investigation focused on enrollment practices at health care providers’ offices for deferred interest credit card plans. The CFPB allegedly found incidences where health care providers: (i) orally misrepresented that the plan has no interest for 12 months as distinct from a deferred interest promotion, (ii) did not provide consumers with copies of the credit agreement or Truth in Lending Act (TILA) disclosures, (iii) failed to disclose the interest rate on the plan once the promotional period expired and (iv) finished incomplete applications and submitted them on behalf of borrowers. The CFPB also noted the lender’s limited involvement in the credit card enrollment process and the lack of training provided to health care providers, many of whom did not understand deferred interest credit cards.
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