CFPB: CFPB Proposes One Year Suspension of CARD Act Required Submission of Credit Card Agreements

The CFPB has proposed a  temporary suspension of card issuers' obligations to submit their credit card agreements quarterly to the CFPB.  The proposal is intended to reduce the burden on the CFPB while it works to develop a more efficient electronic submission system.  Other requirements under the CARD Act, including card issuers' obligation to post their currently offered agreement on their own websites would be unaffected.  The proposed rule was published today and the comment period expires March 13, 2015. 

The provision of the CARD Act in question, 12 C.F.R. 1026.58(c), currently requires card issuers to post agreements for open end consumer credit cards on their website and to submit them quarterly to the CFPB.    Currently, the agreements are manually submitted to the CFPB via email on a quarterly basis.  The disclosed purpose of the proposed suspension is to allow the CFPB time to work on a more streamlined and automated electronic submission system.  The CFPB proposes to suspend the requirement beginning with the April 30, 2015 submission. 

The proposed suspension would not affect the required annual submission of collect credit card agreements and related data, the biannual submission of credit card pricing and availability information, or the requirement that card issuers post agreements on their website.  The CFPB proposes  the modification take effect immediately upon publication of the final rule in the Federal Register.