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April 28, 2016
Credit card agreements due to CFPB Monday
Credit card agreements must be submitted to CFPB by May 2 under a Truth in Lending Act rule set to become effective again April 30.
In February 2015, CFPB issued a proposal to temporarily suspend TILA's requirement that credit unions and other card issuers submit credit card agreements to the bureau quarterly. Now that the rule is being reinstated, credit cards must submit the agreements quarterly unless the credit card agreement previously submitted continues to be offered and has not been amended.
The rule has exceptions for certain private label cards and for credit unions with fewer than 10,000 open credit card accounts.
The credit card agreements must contain the following information:
• identifying information about the credit union, including its name, address and identifying number (such as its tax identification number);
• the credit card agreements offered by the credit union as of the last business day of the preceding calendar quarter that it has not already submitted to the bureau;
• any card agreement previously submitted to the bureau that was amended during the preceding calendar quarter; and
• notification regarding any previously agreement submitted to the bureau that the credit union is now withdrawing.
Agreements must be submitted to CFPB via the email address the bureau has set up: CardAgreements@consumerfinance.gov. More information is available on NAFCU's Compliance Blog.
In February 2015, CFPB issued a proposal to temporarily suspend TILA's requirement that credit unions and other card issuers submit credit card agreements to the bureau quarterly. Now that the rule is being reinstated, credit cards must submit the agreements quarterly unless the credit card agreement previously submitted continues to be offered and has not been amended.
The rule has exceptions for certain private label cards and for credit unions with fewer than 10,000 open credit card accounts.
The credit card agreements must contain the following information:
• identifying information about the credit union, including its name, address and identifying number (such as its tax identification number);
• the credit card agreements offered by the credit union as of the last business day of the preceding calendar quarter that it has not already submitted to the bureau;
• any card agreement previously submitted to the bureau that was amended during the preceding calendar quarter; and
• notification regarding any previously agreement submitted to the bureau that the credit union is now withdrawing.
Agreements must be submitted to CFPB via the email address the bureau has set up: CardAgreements@consumerfinance.gov. More information is available on NAFCU's Compliance Blog.
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