CFPB files Request for Information regarding credit card late fees; could be pre-cursor to introducing new rule

Research evidence excerpt

CFPB files Request for Information regarding credit card late fees; could be pre-cursor to introducing new rule

Equity Research

8 July 2026 | 9:01PM EDT

AMERICAS CONSUMER FINANCE

CFPB files Request for Information regarding credit card late fees; could

be pre-cursor to introducing new rule

On 7/6/2026, the Consumer Financial Protection Bureau (CFPB) submitted for Ryan M. Nash, CFA

+1(212)902-8963 | ryan.nash@gs.com

interagency review a Request for Information Regarding Credit Card late fees and Goldman Sachs & Co. LLC

Late Payments in a pre-rule stage, though we note that the RFI has not been formally Lucas Haimes

released. While there are a handful of potential reasons for the creation of this +1(212)902-3305lucas.haimes@gs.com|

request for information (including, but not limited to 1) updating the factual record, Goldman Sachs & Co. LLC

2) explore whether there are narrower regulatory approaches vs. the 2024 rule or 3)

could be responding to broader policy concerns regarding affordability of consumer

credit), this process can indicate the beginning of a formalized rulemaking process

and has revived a focus from investors on the potential impact to the card issuers

from modification of the safe harbor fee amount for late credit card payments. While

the prior late fee rulemaking was vacated due it violating the CARD Act, we think if

this request for information could be a precursor to revisit late fees caps it likely

presents an overhang for the stocks. That said, we note that any new rulemaking

would likely face significant pushback from the industry (in-line with the prior

litigation) and could look very different from the original proposal, which included an

$8 cap on late fees. While there is the potential to be a wide range of outcomes, for