The CFPB has initiated a public comment period to determine how the Credit Card Accountability Responsibility and Disclosure Act of 2009 has affected the daily lives of consumers and the behavior of industry. Passage of the act was expressly intended to “establish fair and transparent practices related to the extension of credit” in the credit card market. To achieve these purposes, the law changed the requirements applicable to credit card pricing in a number of significant respects. Prior to the CARD Act, the...