Submission of Credit Card Agreements Resume under CARD Act

A year ago, the CFPB temporarily suspended card issuers' obligations to submit their credit card agreements quarterly to the CFPB.  The stated purpose of the rule was to reduce the burden on the CFPB while it works to develop a more efficient electronic submission system.  The suspension has now expired and the CFPB has provided notice to card issuers to resume submitting their currently-offered credit card agreements to the CFPB on May 2, 2016 (the first business day after April 30th).  Regulation Z requires card issuers to submit their currently-offered agreements "in the form and manner specified by the Bureau."  Card issuers' obligation to post currently offered credit card agreements on their publicly available website was not affected by the suspension.  


In other news and perhaps related to the roll out of the CFPB's new electronic submission system, the CFPB rolled out its new website upgrades on April 22, 2016.