According to the
Credit Card Act, which took effect in February 2010, credit-card issuers cannot
charge fees equal to more than 25% of the borrower’s credit limit in the first
year after the account is opened. A question confronting the Consumer Financial
Protection Bureau was whether up-front fees charged before the account is open count toward the limit. The new agency
decided against subjecting such fees to the limit. The question is why.
The full essay is at "Banks Coopting the Consumer Protection Agency."