有什么说法吗 
原文：https://www.banking.senate.gov/imo/media/doc/2026.05.27%20Letter%20to%20Bilt.pdf
Bilt 2.0 immediately debits rent payments, raising questions about compliance with
the Credit CARD Act of 2009
In a major change from Bilt 1.0, Bilt 2.0 immediately debits a customer’s external account for rent or mortgage payments rather than charging the payment against the user’s credit limit and
requiring payment after the user received their credit card statement. Bilt’s new processes potentially implicate the requirements of the Credit Card Accountability Responsibility and
Disclosure Act of 2009 (Credit CARD Act), which requires card issuers to provide users with a statement at least 21 days before payment is due in order to charge any late fees. However, in Bilt 2.0, rent and mortgage payments are withdrawn before a statement is issued and are not charged against customers’ credit limits, but are still listed alongside all of a customer’s other transactions in Bilt’s app. Bilt appears to be treating its credit cards as debit cards for a subset of purchases and credit cards for others, raising questions about how Bilt’s processes, including for users who link their account to Venmo, are designed to be compliant with all the requirements of the Credit CARD Act.
