How PerformLine helped a leading bank prepare for impending regulatory changes in less than 48 hours

About the Client

As a leading global financial institution, this bank offers a wide range of financial products and services to consumers, corporations, governments, and institutions. With a global presence, this bank is renowned for its comprehensive suite of services, including personal banking, credit, corporate and investment banking, securities brokerage, and wealth management.

By leveraging its extensive network and expertise, the bank aims to foster economic growth and stability while ensuring a seamless and secure banking experience for its customers worldwide.

Business Challenges

In early 2024, the Consumer Financial Protection Bureau (CFPB) introduced a new rule capping credit card late fees at $8 for banks managing over one million credit card accounts. This rule, scheduled to take effect on May 14th, 2024, mandated that all relevant materials be updated to reflect the new late fee limit.

However, the implementation of this rule faced significant opposition from industry groups, which filed a lawsuit challenging its validity. As a result, the rule's future became uncertain, with a final court decision expected by May 10th, just days before the rule's intended enforcement date.

Amid this uncertainty, this bank, which currently offers over a dozen different credit cards, wanted to proactively identify all instances where its late fees were mentioned online.

This preparation was crucial to ensure that they could quickly update their materials in compliance with the effective date in the event that the rule wasn’t blocked.

The bank knew they couldn’t do this manually, so they turned to PerformLine to help identify all pages that needed updates within the tight deadline.

PerformLine Solutions

• Discovery to find previously unknown web pages where their credit card offers were being promoted using our proprietary crawler
• Web Monitoring to automatically monitor all known web pages that include credit card offers and information across their corporate website and third party partners

The Results

Identified thousands of web pages that would need updates in just 48 hours

Using PerformLine, this bank identified over 7,600 web pages that would need to be updated with the new late fee threshold. Not only did PerformLine identify all of these web pages for updates, but this was all accomplished in less than 48 hours.

Working against a tight deadline, this daunting task would have been impossible to achieve through manual efforts alone. 

Uncovered over 4,500 previously unknown web pages with credit card promotions

PerformLine uncovered over 4,500 web pages that promoted credit card offers that were previously unknown to the bank, significantly broadening the scope and coverage of compliance oversight without the need for increased headcount or additional work hours. 

Prepared for any future regulatory changes

While the rule didn’t go into effect on the intended date, the bank was still prepared to make these updates within a very short turnaround time if it did pass.

The rule was blocked, citing the pending Supreme Court decision on the constitutionality of the CFPB’s funding structure. But, the CFPB’s funding structure has since been ruled constitutional. So now, as the rule heads back to court, and could potentially be passed in the future, the bank remains confident in its readiness to comply quickly.

Increased confidence in compliance oversight and future regulatory changes

Now, not only can the bank be confident that it’s prepared to make necessary changes to the CFPB’s late fee rule, but it also has newfound confidence that it can be prepared to comply quickly with any regulatory update in the future that requires mass updates across marketing materials, whether from the CFPB or any other federal or state regulator.

The bank also has increased confidence in its overall compliance oversight of its card offerings across the web. The bank can now regularly monitor those recently discovered 4,500+ pages for compliance with all regulations, not just the CFPB’s late fee rule.