On February 26, 2015, the Consumer Financial Protection Bureau (“CFPB”) published a proposed rule (“Proposed Rule”) that would suspend for one year the requirement that credit card issuers submit their agreements to the CFPB on a quarterly basis, as required by the Truth in Lending Act, as amended by the Credit Card Accountability Responsibility and Disclosure Act (“CARD Act”) and implemented by Regulation Z. During that time, the CFPB says it will work to develop a new electronic submission system that would make submitting credit card agreements less burdensome for issuers in the future. Comments on the CFPB’s proposal are due by March 13, 2015.
CURRENT CARD ACT POSTING REQUIREMENT -
Regulation Z requires that credit card issuers submit agreements to the CFPB each quarter so that the CFPB can add the agreements to its online repository. The repository currently contains agreements from close to 450 card issuers. Separately, Regulation Z also requires issuers to post agreements on their own Web sites in a prominent location.
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