On April 15, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced a final rule (“Final Rule”) that suspends for one year the requirement under the Truth in Lending Act and implemented by Regulation Z that credit card issuers submit their card agreements to the CFPB on a quarterly basis. The Final Rule adopts the February 2015 proposed rule and took effect immediately upon its April 17, 2015, publication in the Federal Register.

During the suspension period, the CFPB will work to develop a “streamlined and automated electronic submission system” that will enable issuers to upload agreements directly to the CFPB’s online repository.