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Financial Services Law Insights and Observations

CFPB Seeks to Improve Process for Industry Submission of Consumer Credit Card Agreements

Credit Cards CFPB Disclosures

Consumer Finance

On February 24, the CFPB announced a proposed rule that would reduce the burden of credit card issuers by suspending - for one year - their obligation to submit credit card agreements to the CFPB on a quarterly basis. The proposed rule would be in effect while the CFPB works to establish a “more streamlined and automated electronic submission system” that would make it easier for issuers to submit the agreements. The proposal amends the 2009 CARD Act, which established the requirement that issuers submit consumer credit card agreements to the CFPB. During the proposed one-year suspension, other requirements of the CARD Act would remain in place, such as the issuers’ “obligations to post currently-offered agreements on their own websites.” Comments on the proposed rule are due by March 13. Credit card issuers would resume submitting credit card agreements on a quarterly basis to the CFPB starting on April 30, 2016.