The CFPB has issued guidance to credit card issuers regarding the resumption of the requirement to submit card agreements to the CFPB on a quarterly basis. The next submission is due on or before May 2, 2016.
In April 2015, the CFPB issued a final rule that suspended 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 final rule suspended 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. The suspension was intended to reduce the burden on issuers while the CFPB updated its submission system.
By May 2, issuers must submit to the CFPB all credit card agreements offered to the public as of the end of March 2016. The guidance provides instructions for an issuer to follow in submitting card agreements (which can be done by sending an email to the CFPB with links to the agreements posted on the issuer’s public website.) After the May 2 deadline, the remaining 2016 submission deadlines are August 1 and October 31. The guidance also includes answers to a series of questions.
The CFPB also published a “Notice of expiration of suspension” in today’s Federal Register. The notice indicates that submission instructions are available on the CFPB’s website.