ST. PETERSBURG, Fla.—Any issuer of credit must submit their current credit card (consumer) agreements to the CFPB via email to CardAgreements@consumerfinance.gov no later than May 2, PSCU is reminding.
This requirement was in effect in the past and was suspended, but it has been reinstated. This is a quarterly submission and the next due dates are Aug. 1 and Oct. 31. The Aug. 1 deadline applies to agreements offered to new customers on June 30, while the Oct. 31 deadline applies to agreements offered to new customers on Sept. 30.
Regulation Z, which implements the Truth In Lending Act, contains several requirements for issuers, pointed out PSCU via the company’s The Payments Review website. Reg Z requires issuers of credit cards to post on their public website a complete set of the consumer credit card agreements that are offered to consumers, and to make these agreements available to cardholders. It also created a requirement for the issuer to submit the same agreements as the one posted on the issuer’s website to be submitted to the CFPB, which in turn maintains a public database on its website of these credit card agreements from nearly 450 card issuers. Issuers must submit agreements on a quarterly basis, PSCU stated.
In 2015, the CFPB set out to streamline the submission process. In order to reduce the burden on issuers during the transition period, the requirement for quarterly submission was suspended for the April 30, 2015; July 31, 2015; Oct. 31, 2015; and Jan. 31, 2016 submission dates. The requirement for cardholder disclosure and posting on the issuer’s website was not suspended, PSCU reminded.
Regulation Z provides that card issuers shall submit their currently offered agreements “in the form and manner specified by the Bureau.” The CFPB states that the new method of submission is:
“emailing us links to (or webpage addresses for) the consumer credit card agreements that you post on your public website. Current regulations require you to post on your public website a complete set of the consumer credit card agreements that you offer to consumers. (§ 1026.58(d).) The agreements you have to post on your public website are the same as those you need to submit to the Bureau. As a result, sending us the relevant links or webpage addresses is the easiest and most straightforward way to meet your submission requirement.
“Include in your email the name and address of the issuer that offers the product, plus a unique identifying number for the issuer such as a DUNS or RSSD number. Sending us that identifying information plus links or webpage addresses to your properly posted agreements is sufficient to meet all your submission obligations under § 1026.58(c). No other information is required.
“Although the Bureau believes that issuers will generally find that emailing agreement links or webpage addresses to the Bureau is the fastest and simplest way to submit the required agreements, you may also comply by emailing us PDF copies of all the agreements you offered to the public as of the end of March 2016. Alternatively, you may email us the agreements and information identified in § 1026.58(c)(1)(ii), (iii), and (iv). Whatever submission method you choose, remember to include your identifying information.”
Financial institutions with fewer than 10,000 open credit card accounts as of the last business day of the calendar quarter are exempt from this requirement.