The Consumer Financial Protection Bureau's new online form soliciting complaints about credit cards may cast an unflattering light on card issuers’ risk-management strategies. The form asks “a lot of leading questions,” according to Ballard Spahr partner Alan Kaplinsky. “I think (the Bureau) will elicit lots of complaints from cardholders which are not based on actual violations of law,” Mr. Kaplinsky said.

Simplifying credit card disclosures—a CFPB mandate—for the public is a tall order for issuers and could result in elimination of certain products and fees. To date, the Bureau has not reported the number of complaints that have been lodged against issuers online.