Comments on Proposed Revisions to Ability-to-Pay Requirement

On behalf of the Retail Industry Leaders Association (RILA), I offer the following comments in response to the Board of Governors of the Federal Reserve System’s (FRB) Proposed Rule regarding a requirement that credit card issuers assess a consumer’s ability to pay before opening a new credit card account or increasing the credit limit on an existing account (Proposed Rule). 1


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