On January 31, 2013, the Consumer Financial Protection Bureau (“CFPB”) published a notice in the Federal Register seeking information regarding the impact of financial products marketed to students enrolled in institutions of higher education (the “Notice”). Although the Credit Card Accountability, Responsibility and Disclosure Act of 2009 includes requirements that financial companies publicly disclose credit card agreements with colleges, universities and alumni associations, less is known about other financial products marketed to students, including debit cards to access student loan funds and bank accounts. At this time, we can only speculate about the outcome of the CFPB’s inquiry, but it is possible that it may lead to requirements, similar to those relating to credit cards, that financial companies publicly disclose these types of agreements with institutions of higher education.
The CFPB “seeks information on how partnerships between institutions of higher education…and financial institutions might be structured to promote positive financial decision-making among young consumers.”
Emphasis on Campus-Affinity Relationships
The Notice makes clear that the CFPB is particularly interested in the impact of campus-affinity relationships on the student financial product market. Specifically, the CFPB seeks information on (1) products marketed through campus-affinity relationships and (2) other financial products marketed to students.
According to the CFPB, campus affinity products “are generally financial products and services that carry an endorsement (either explicit or implicit) or mark of an institution of higher education,” including “products that display the name or mark of the institution, are bundled with student identification cards, and cards on which students receive disbursements of financial aid or other funds from the institutions of higher education.” Although the CFPB’s Request for information includes a lengthy list of questions, the following questions may be of particular interest to financial institutions:
The deadline to submit comments is March 18, 2013.