Banking and Finance Law Daily Wrap Up, CREDIT, DEBIT AND GIFT CARDS—Advocacy group Protect Borrowers requests CFPB investigation of Bilt Technologies, (Mar 13, 2026)

By Charles A. Menke, J.D.

The organization expressed concerns over reports concerning Bilt’s change of credit card bank partner that suggest consumers are being put at risk.

The nonprofit organization Protect Borrowers, formerly known as the Student Borrower Protection Center, has written to Consumer Financial Protection Bureau Acting Director Russell Vought, requesting the agency to initiate an investigation into Bilt Technologies, Inc., over “potential and ongoing risks for consumers stemming from Bilt’s conduct as a credit card issuer.” According to Protect Borrowers, “[e]vidence suggests that the firm is mismanaging its transition to a new bank partner and that, over this transition period, consumers have encountered a stunning range of harmful errors and breakdowns.”

In the letter to Vought, Protect Borrowers described Bilt as “a fintech company that offers a credit card that its customers (known as ‘members’) can use for purposes that uniquely include making rent and mortgage payments.” While Bilt’s cards had been issued through Wells Fargo, Bilt announced earlier this year “it would be replacing its existing credit card product with a new menu of cards dubbed ‘Bilt Card 2.0’ … in partnership with Column Bank,” the letter said. “Bilt indicated that existing users could either opt to stay with Wells Fargo and receive a Wells Fargo Autograph card or move to a Bilt 2.0 card with Column Bank. For users who might opt to transition, Bilt promised that the change would be ‘seamless.’”

According to Protect Borrowers, “[m]ounting evidence suggests Bilt has put consumers at risk by mishandling its change in bank partners.” Citing various reports, Protect Borrowers contended the transition “has been disastrous” and “could generate a broad set of second-order risks across the economy.” The organization specifically noted several consumer harms resulting from Bilt’s actions, including: mismanaged or unaccounted for rent payments; poor customer service provided by AI chatbots; bait-and-switch marketing and rewards offers; and disabled or denied account access. The organization further warned of “potential harm to landlords who may not receive timely rent payments as a result of Bilt’s conduct, and possible damage to merchants who may miss out on business as a result of Bilt’s reported processing issues.” Protect Borrowers added that “these reports suggest that Bilt is unable to deliver on its obligations and commitments to its customers, and that a variety of other companies may have been involved in the company’s failures.”

The letter suggested that the described practices may violate the 2009 CARD Act and the Truth in Lending Act (TILA). Protect Borrowers also questioned the role of Wells Fargo and Column Bank, as well as the nonbank issuer-processer Cardless which the letter said acts as a servicer for Bilt.

Based on the foregoing, Protect Borrowers said “[t]he CFPB must immediately invoke its risk-based supervisory authority and examine Bilt.” The organization noted that Wells Fargo and Cardless come within the definition of “covered persons” under the Consumer Financial Protection Act and that “Bilt meets all the risk-based qualifications for CFPB supervision” based on the cited reports that “point to potential and ongoing risks for consumers stemming from Bilt’s conduct as a credit card issuer.” The letter further contended that “Bilt’s conduct shows the vulnerabilities and risks that can arise when fintech companies become reliant on AI-based chatbots to provide customer service.”

Companies: Bilt Technologies, Inc.; Cardless; Column Bank; Protect Borrowers; Wells Fargo

RegulatoryActivity: BankingOperations CFPB ConsumerCredit CreditDebitGiftCards FinancialIntermediaries FinTech UDAAP