Reinstate Quarterly Credit Card Submissions

CONSUMER FINANCIAL PROTECTION BUREAU
NO-MATERIAL NONSUBSTANATIVE CHANGE REQUEST
CONSUMER AND COLLEGE CREDIT CARD AGREEMENTS
(OMB CONTROL NUMBER: 3170-0052)

The Consumer Financial Protection Bureau (CFPB) submits this memorandum to provide justification for a proposed change to an
information collection approved under this OMB control number, namely the “Quarterly Credit Card Agreement Submission.”
Credit card issuers are required to submit quarterly reports to Consumer Financial Protection Bureau detailing the terms of credit cards
they offer to consumers under sections 204 and 305 of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD
Act) (P.L. 111–24) and 12 C.F.R. §§ 226.57(d) and 226.58. This information collection is approved by OMB under control number 31700052
In a Final Rule published April 17, 2015, in the Federal Register at 80 FR 21153, the CFPB has suspended, for one year, the requirement
that respondents submit this information. The suspension was designed to allow the CFPB to modernize and streamline the system by
which such information is received to make the information more useful to the Bureau and the submission process less burdensome to
respondents.
Therefore, the CFPB submitted a non-material program adjustment to this collection removing the burden hours associated with the
suspended collection for a period of one year and indicating that at such time as the reporting requirement is reinstated, the Bureau will
recalculate the burden of this information collection using the new submission methods and report it accordingly.
The aforementioned Final Rule provides, among other things, that “Beginning with the submission due on the first business day on or after
April 30, 2016, card issuers shall resume submitting credit card agreements on a quarterly basis to the Bureau pursuant to Sec. 1026.58(c).
A card issuer shall submit agreements for the prior calendar quarter (that is, the calendar quarter ending March 31, 2016), as specified in
Sec. 1026.58(c)(1)(ii) through (iv) and (c)(3) through (7), to the Bureau no later than the first business day on or after April 30, 2016.”
Therefore, the CFPB is submitting this change request to timely reinstate the subject Quarterly Credit Card Agreement Submission and
adjust the burden inventoried under OMB control number 3170-0052.
CFPB assumes the number of respondents for both the consumer and college credit card collections will remain the same as previously
estimated. The increase in burden results from reinstating the consumer credit card agreement collection that, as noted above, was
suspended for a period of one (1) year. CFPB also notes that new streamlined submission process is estimated to reduce the average
response time for the Quarterly Credit Card Agreement Submission from 15 minutes to 5 minutes resulting in an estimated reduction 267
hours (or, 10 minutes per respondent). The net result is that there is a 128 burden hour increase resulting from reinstating the Quarterly
Credit Card Agreement Submission.

Summary of Burden
Responses

Quarterly Credit Card
Agreement Submission
Annual College Credit
Card Agreement
Submission
Total Burden:

Frequency

400

Quarterly (4)

1,600

Estimated
Average
Response Time
(hours)
.08

30

Annually (1)

30

1

30

1,630

/////////////

158

430

Number of
Annual
Responses

/////////////

Estimate
Annual
Burden
Hours
128

Summary of Burden Changes
Total Respondents
Total Annual Burden Requested
Current OMB Inventory
Difference (+/-)
Program Change
Discretionary
New Statute
Violation
Adjustment

430
30
400
400
400
0
0
0

Annual
Responses
1,630
30
1,600
1,600
1,600
0
0
0

Burden Hours
158
30
128
128
128
0
0
0

Cost Burden
(O & M)
0
0
0
0
0
0
0
0