Checks credit-card underwriting against the CARD Act ability-to-pay rules per Reg Z §1026.51: income and asset sufficiency test, under-21 cosigner or independent income requirement, and §1026.52(b) penalty-fee safe harbors ($32 first violation, $43 subsequent). The CFPB late-fee $8 rule was vacated by the Fifth Circuit on January 17, 2025 — $32/$43 thresholds remain in force pending further rulemaking.
Reg Z §1026.51Reg Z §1026.52(b)CARD Act 2009Under-21 Rule$32/$43 Safe Harbor$8 Rule Vacated Jan 2025
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ⓘ Not legal or compliance advice. The CFPB $8 late-fee rule (88 FR 18906) was vacated by the Fifth Circuit Court of Appeals on January 17, 2025 (Chamber of Commerce v. CFPB, No. 24-10266). The $32/$43 penalty-fee safe harbors under §1026.52(b) remain current law. Verify applicant age and income independently before underwriting decisions.
Applicant Profile
Under-21 triggers cosigner or independent income requirement (§1026.51(b)).
Independently verifiable income. For applicants under 21, must be their own income.
Liquid assets available to service the credit line.
All recurring monthly debt payments (auto, student, etc.) excluding housing.
Under-21 / Cosigner
Satisfies the under-21 independent-means exception (§1026.51(b)(1)(ii)).
Monthly minimum payment as % of balance (typically 1–2%). Used for ATP ratio check.