International Financial Law Prof Blog.
The Bank marketed the “PAYS Plan,” a payment protection credit card add-on product that was sold from 2008 to 2013 to consumers who had a Bank credit card. The PAYS Plan provided a benefit payment towards a consumer’s monthly credit card payment following certain life events such as involuntary unemployment, disability, and hospitalization.
The FDIC determined that the Bank violated federal law prohibiting unfair and deceptive practices by, among other things: …
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