The CFPB has issued a final rule adopting its proposal to suspend for one year the Truth in Lending Act/Regulation Z requirement for issuers of open-end credit cards to send their credit card agreements to the CFPB quarterly for posting in a public database on the CFPB’s website. The suspension does not affect the TILA/Reg Z requirement for such issuers to post their credit card agreements on their own publicly available websites. The suspension will be effective immediately upon the rule’s publication in the Federal Register (which is scheduled for
April 17, 2015) and is intended to reduce the burden on issuers while the CFPB works to develop a new automated electronic system that will allow issuers to upload agreements directly to the CFPB’s database.
The final rule suspends the submission requirement for the submissions that would otherwise have been due to the CFPB by the first business day on or after April 30, 2015; July 31, 2015; October 31, 2015; and January 31, 2016. Issuers will be required to resume submitting credit card agreements beginning with the submission due on the first business day on or after
April 30, 2016. In lieu of providing new and amended agreements and notice of withdrawn agreements for the April 30, 2016 submission, issuers will be permitted to submit to the CFPB a complete, updated set of agreements offered to the public as of the calendar quarter ending March 31, 2016.