CFPB Finalizes Rule Aimed at Improving Credit Card Agreement Submission Process

The Consumer Financial Protection Bureau (CFPB) Wednesday issued a final rule aimed at improving the way that companies submit consumer credit card agreements to the Bureau.

The rule temporarily suspends a requirement that each quarter certain credit card issuers send their agreements to the Bureau, which publishes them in a public database on its website. Other requirements, including card issuers’ obligations to post these agreements on their own publicly available websites, will remain unaffected by the rule.

“Today we are finalizing a rule that will help further the Bureau’s work to improve the public credit card agreements database,” said CFPB Director Richard Cordray.  “Updating and streamlining the process for how credit card companies submit their agreements to us can benefit industry and our agency. Improving this process can also enable consumers and others to access the data faster and in a more useable form. ”

In 2009, Congress passed the Credit Card Accountability, Responsibility, and Disclosure (CARD) Act, which requires that credit card issuers post consumer credit card agreements on their websites as well as submit those agreements to the CFPB. These agreements feature general terms and conditions, pricing, and fee information. The CFPB maintains a public database on its website of these credit card agreements from nearly 450 card issuers. Federal regulations require that companies submit their agreements to the CFPB on a quarterly basis.

The final rule issued by the Bureau today suspends for one year credit card issuers’ obligations to submit their credit card agreements to the Bureau. During this time, the Bureau will work to develop a more streamlined and automated electronic submission system. The Bureau intends for its new submission system to be easier for issuers to use than the current manual submission system. The CFPB also intends for the new system to enable faster posting of new and revised agreements on the Bureau’s website. In designing the new system, the Bureau also intends to explore improved reporting formats for the posted information.

Under the rule, credit card issuers will not be required to submit agreements that would otherwise have been due to the Bureau by the first business day on or after April 30, July 31, and October 31 of 2015, and January 31, 2016. Credit card issuers must resume submitting credit card agreements on a quarterly basis to the Bureau starting on April 30, 2016.

During the temporary suspension period, the CFPB will collect consumer credit card agreements from the largest card issuers’ public websites and post the agreements to its online consumer credit card agreements database. This will help ensure that the database contains agreement terms that are currently offered to consumers by credit card issuers responsible for the substantial majority of existing and new credit cards in the U.S. 

The rule is available here: http://files.consumerfinance.gov/f/201504_cfpb_final-rule_credit-card-collection-suspension.pdf