“And we are no longer assuming that the CFPB late fee rule will be implemented in 2024, given ongoing uncertainty around industry litigation.”

In context

“the third consecutive quarter and consumer credit trends remained stable. Our year-to-date operating efficiency ratio, net of adjustments through September was 41.7%. We had guided to 2024 annual operating efficiency ratio, net of adjustments to be modestly down compared to the 43.5% we posted in 2023. Our view included the positive impact from the end of the revenue sharing related to the Walmart partnership and assumed the CFPB late fee rule would take effect in October. Looking forward, we now expect the full year 2024 annual operating efficiency ratio net of adjustments to be in the low 42s. We expect a sequential quarter increase in operating expense in the fourth quarter, that will be roughly in line with historical patterns as we continue to invest in our technology transformation. And we are no longer assuming that the CFPB late fee rule will be implemented in 2024, given ongoing uncertainty around industry litigation. Our view of 2024 marketing has not changed. We continue to lean into marketing to grow and to further strengthen our franchise. In the Domestic Card business, we continue to get traction in originations across our products and channels. In Consumer Banking, we're leaning into marketing to grow our digital first national banking franchise. We continue to expect total company marketing in the second half of 2024 to be meaningfully higher than in the first half, similar to the pattern we saw last year and that includes the much higher marketing levels that we typically see in the fourth quarter. And turning to the Discover acquisition, we're working closely with the regulators as our applications continue to work their way through the regulatory approval process. Separately, Discover mention”