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Financial Services Law Insights and Observations

CFPB releases TILA and CARD Act specifications

Federal Issues CFPB Regulation Z TILA CARD Act Dodd-Frank Ability To Repay Qualified Mortgage

Federal Issues

On August 20, the CFPB released new technical specifications regarding credit card agreement and data submission compliance requirements under TILA and the CARD Act (Regulation Z).  Credit card issuers will utilize the Bureau’s website to submit: (i) Terms of Credit Card Plans (TCCP) Survey data (for the deadline of February 14, 2022); (ii) quarterly credit card agreement submissions (for the deadline of January 31, 2022); and (iii) annual reports connected to college credit card marketing agreements and data (for the deadline of March 31, 2022). According to the announcement, for the most recent TCCP Survey cycle that started on January 31, 83 percent of TCCP Survey submissions were made via the Bureau’s “Collect” website on a voluntary basis, which simplified the Survey submission process in a number of ways, including by minimizing confusing, irrelevant, or duplicative questions and providing an “audit trail” to track submissions. In addition, the Bureau understands Collect to be faster both for issuers and for Bureau processing, which “has led to the faster posting of the TCCP Survey results” and enhances the “public’s ability to use the data in a timely manner.” The Bureau believes that these benefits “would be increased if all TCCP Survey respondents used Collect, and that any additional burden on Survey respondents as a result of using Collect would be minimal.” As previously covered by InfoBytes, the CFPB released the final rule revising the dollar amounts for provisions implementing the TILA and amendments to TILA, including CARD Act, the Home Ownership and Equity Protection Act of 1994, and Dodd-Frank’s ability-to-repay and qualified mortgage provisions. The recently released rule took effect upon publication in the Federal Register.