ARLINGTON, Va.—NAFCU is supporting the CFPB’s recent efforts to reduce the regulatory burden on FIs. The trade association sent a letter Friday to the bureau that backs the CFPB’s proposal to temporarily suspend card agreement submissions to the agency (CFPB To Reduce FI Reg Burden).
The proposal seeks to amend Regulation Z, which implements the Truth in Lending Act, and the official interpretation to that regulation. The proposal would suspend card issuers’ obligations to submit quarterly credit card agreements to the bureau for a period of one year, as the CFPB works to develop a more streamlined and automated electronic submission system.
Other requirements, including card issuers’ obligations to post currently offered agreements on their own websites, would remain unaffected.
"Credit unions consistently strive to provide their members with the type of information useful to determining which products best fit the member’s individual financial needs and goals," NAFCU Director of Regulatory Affairs Alicia Nealon wrote in her letter. "The development of a more efficient and user-friendly system of submitting credit card agreements for posting on the CFPB website is a significant step toward furthering that mission."
Nealon said in the letter that NAFCU members have expressed concerns with the bureau’s current e-mail submission procedures. Some of those concerns include confusion and inconvenience for card issuers as well as consumers; lengthy waits for agreements to appear on CFPB’s website; and difficulty tracking and eliminating outdated or invalidated agreements.
In the letter, Nealon also noted that CFPB’s recent proposed rule involving prepaid accounts would apply the same submission requirements as credit card agreements. Nealon recommended that “CFPB’s agreement submission mechanism should be thoroughly ‘worked out’ before any final rule on prepaid accounts is promulgated or effective.”