CFPB Action to Require Citizens Bank to Pay $9 Million Penalty for Unlawful Credit Card Servicing

  • Source:

Treliant Takeaway:

Regulatory oversight has increased across the Payments Industry. Treliant offers comprehensive consulting services to payments services providers. We assist credit, debit, and prepaid card issuers, sellers, and servicers, ACH originators and receivers, and payment app providers in developing programs that comply with regulatory expectations and industry best practices. Treliant works with clients to perform strategic, operational, regulatory, and risk governance assessments to identify opportunities and gaps.  Partner with us to enhance your institution’s card compliance practices, protect your reputation, and achieve long-term success.


The bank is alleged to have violated consumer financial protection laws and rules related to credit card disputes and fraud claims. The CFPB claims the bank failed to properly manage and respond to customer credit card disputes and fraud claims.  The CFPB states that the bank failed to reasonably investigate and resolve billing errors, did not properly credit customer’s accounts, nor provide required notices.

The CFPB is requiring the bank to:

  • Correct its dispute practices as it relates to the handling and resolution of billing error notices and unauthorized use claims and to no longer require fraud affidavits to support a credit card claim; and
  • Ensure that refunds of fees and other amounts are calculated from the date of the error or unauthorized use.

Next Steps:

  • Card Issuing Institutions should review their dispute and billing error policies, procedures, and practices to ensure adherence with the Truth in Lending Act and its implementing Regulation Z

Additional Resources:

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Patricia Ryan

Pat Ryan, Engagement Director at Treliant, is a senior banking executive with 40 years’ experience at US Bank, Capital One, and FleetBoston Financial. She is an expert in creating and managing robust risk management, compliance, and regulatory policies and procedures, as well as leading business transformation efforts. Her areas of…