CFPB Approves Synchrony's "Dual-Feature Credit Card"

On December 30, 2020, the CFPB approved Synchrony Bank's application to offer a "dual-feature credit card" (DFCC) under the CFPB's Compliance Assistance Sandbox (CAS) policy. According to Synchrony's application, the DFCC allows consumers to graduate from a secured-use credit card to an unsecured feature after at least one year and if the customer satisfies certain eligibility criteria.

The CAS policy, which was finalized in September 2019, has the "primary purpose" of "provid[ing] a mechanism through which the Bureau may more effectively carry out its statutory purpose and objectives by better enabling compliance in the face of regulatory uncertainty." The CFPB's approval of an application under the CAS policy "enable[es] compliance in the face of regulatory uncertainty." Since September 2019, the CFPB has approved one other application under the CAS policy for Payativ, Inc., involving what it described as an "Earned Wage Access" (EWA) program.