In August 2017, the CFPB took action against two American Express subsidiaries for charging “higher interest rates and annual fees” to cardholders in “overseas territories of the United States,” including Puerto Rico, than to customers in the mainland United States. American Express paid over $95 million to compensate harmed consumers.

•  On August 23, 2017, the CFPB issued a consent order to American Express Centurion Bank and American Express Bank, FSB, subsidiaries of American Express Company. [CFPB 2017-CFPB-0016 (American Express Centurion Bank and American Express Bank, FSB), filed 08/23/17]

• “Under the Order, the CFPB and the banks agreed to a compliance plan and audit, in addition to the banks’ voluntary provision of $95 million in remediation. At issue were the banks’ practices in overseas territories of the United States, including Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa and the Northern Mariana Islands.” [“CFPB alleges disparate treatment in Amex’s US territories’ credit and collection practices,” Baker and Hostetler LLP, 09/26/17]

• “American Express charged higher interest rates and annual fees for more than a decade to cardholders in Puerto Rico, the U.S. Virgin Islands and other U.S. territories, compared with customers in the U.S., the Consumer Financial Protection Bureau said Wednesday. […] The company said it ‘voluntarily’ paid $95 million in remediation, including nonmonetary relief, to more than 220,000 consumers. The CFPB did not impose any fines or penalties because American Express self-reported the issue in 2012, provided relief to consumers, and cooperated with the investigation. American Express will pay at least another $1 million ‘to fully compensate harmed consumers,’ the agency said.” [Kate Berry, “Amex charged higher rates and fees in U.S. territories, CFPB says,” American Banker, 08/23/17]