CFPB Technical Specifications for Credit Card Issuers

Kaufman & Canoles

Kaufman & Canoles

As part of an effort to modernize and streamline certain submission practices for credit card issuers, the Consumer Finance Protection Bureau (“CFPB”) now mandates credit card issuers to submit certain reporting requirements under the Truth in Lending Act (“TILA”) and the Credit Card Accountability Responsibility and Disclosure Act (“CARD Act”) to the agency’s existing online and interactive platform called Collect. As reference to the applicable rules, please refer to 12 CFR § 1026.58.

In 2018, the CFPB provided selected credit card issuers with the option to voluntarily submit online with Collect. Now, effective August 23, 2021, certain submissions under both TILA and the CARD Act to Collect are mandatory.

Under the TILA, credit card issuers, from time to time and randomly selected, are required to participate in the Terms of Credit Card Plans Survey (“TCCP Survey”). Under the new guidance, selected credit card issuers participating in the TCCP Survey cycle beginning on January 31, 2022 will be the first cohort required to submit via Collect no later than February 14, 2022.

Additionally, pursuant to the CARD Act and TILA, the CFPB now also requires the quarterly credit card agreement submissions as required under the CARD Act to be submitted via Collect beginning with credit card issuers’ fourth quarter of calendar year 2021.

Lastly, under the two statutes, credit card issuers are required to submit annual reports in connection to college credit card marketing agreements and certain data. Credit card issuers must now submit via Collect no later than March 31, 2022 for agreements and materials made during calendar year 2021.

The quarterly credit card agreement and annual college credit card marketing agreements submissions must be in text searchable, digitally-created PDF format; in other words, scanned “image only” PDFs are not acceptable.

To register for Collect, please visit the following link here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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