On June 22, 2022, the Consumer Financial Protection Bureau issued an Advanced Notice of Proposed Rulemaking (“ANPR”) requesting information regarding credit card late fees, late payments, and card issuers’ revenue and expenses. The principal purpose of the ANPR is to gather information relevant to potential revisions to the credit card fee “safe harbor” in the CFPB’s Regulation Z. The safe harbor and related provisions implement the Credit Card Accountability Responsibility and Disclosure Act (the “CARD Act”) and were first promulgated by the Board of Governors of the Federal Reserve System (the “Federal Reserve”) in 2010. The safe harbor establishes a presumption that a fee is permissible provided it does not exceed the dollar amounts set out in the safe harbor. Rulemaking authority under the CARD Act was transferred to the CFPB in 2011. Since then, the CFPB’s only adjustments to the safe harbor have been to increase the specified amounts to account for inflation. Now, however, the CFPB appears to view the safe harbor as “allow[ing] credit card issuers to escape enforcement scrutiny” for excessive late fees and, therefore, warranting reconsideration.