Dear Boards of Directors and Chief Executive Officers:
On August 20, 2021, the Consumer Financial Protection Bureau (CFPB) issued new technical specifications for complying with credit card agreement and data submission requirements under the Truth in Lending Act and the Credit Card Accountability Responsibility and Disclosure Act of 2009.1 To comply with these two laws, credit unions with applicable credit card portfolios will make the required submissions through the CFPB’s Collect website (opens new window). Credit unions can begin submitting the following data to the CFPB using Collect, starting with listed submission dates:
- Terms of Credit Card Plans (TCCP) Survey data (for the February 14, 2022, deadline),
- Quarterly credit card agreement submissions (for the January 31, 2022, deadline), and
- Annual reports related to college credit card marketing agreements and data (for the March 31, 2022, deadline).
To use the Collect website, credit unions must complete the Collect registration form (opens new window) and send it to Collect_Support@cfpb.gov. Credit unions that have registered for Collect in the past do not need to register again.
Credit unions that are selected to participate in the TCCP Survey or are required to submit an annual report of college student credit card agreements pursuant to 12 CFR 1026.57(d) (opens new window) may register now. Any credit union with 10,000 or more credit card accounts as of any quarter-end is required to make quarterly credit card submissions to the CFPB pursuant to 12 CFR 1026.58(c) (opens new window) and must register for Collect by November 1, 2021.2 Once a credit union receives its login credentials, it will be able to review its current submissions and make the required submissions for the fourth quarter of calendar year 2021 starting on December 1, 2021. For more details, view the technical specifications for the system on the CFPB’s website (opens new window).
The CFPB is in the process of updating and publishing resources to help card issuers use Collect. Existing TCCP Collect resources can be accessed on the CFPB’s website (opens new window). The CFPB will continue to publish resources for the quarterly credit card agreement submissions and annual reports related to college credit card marketing agreements and data online (opens new window).
If you have questions about the information in this Regulatory Alert, please contact the NCUA’s Office of Consumer Financial Protection at 703.518.1140 or ComplianceMail@ncua.gov. You can also contact your NCUA regional office or state supervisory authority.
Todd M. Harper