Download:
pdf |
pdfThe Truth in Lending Act (TILA) and Regulation Z (12 CFR 1026) require credit card issuers to
submit their currently-offered credit card agreements on a quarterly basis to the Consumer
Financial Protection Bureau (Bureau), to be posted on the Bureau’s website.
The next submission is due from issuers on January 31, 2018. This document specifies how to
submit your credit card agreements. Please follow these instructions. Please also note the
submission deadlines for 2018. We are no longer sending emails reminding issuers of their
submission obligations.
You may also consult the relevant Bureau regulation, which is 12 CFR § 1026.58(c). You can
access an unofficial version of that rule via our “eRegulations” webpage at
http://www.consumerfinance.gov/eregulations/.
What do I submit?
For the next submission, you must make sure you have submitted to the Bureau all of the
agreements that you offered to the public as of the end of December 2017.
You can do this by emailing us links to (or webpage addresses for) the consumer credit card
agreements that you post on your public website. Current regulations require you to post on
your public website a complete set of the consumer credit card agreements that you offer to
consumers. (§ 1026.58(d).) The agreements you have to post on your public website are the
same as those you need to submit to the Bureau. As a result, sending us the relevant links or
webpage addresses is the easiest and most straightforward way to meet your submission
requirement.
Include in your email the name and address of the issuer that offers the product, plus a unique
identifying number for the issuer such as a DUNS or RSSD number. Sending us that
identifying information plus links or webpage addresses to your properly posted agreements is
sufficient to meet all your submission obligations under § 1026.58(c). No other information is
required. (Comment 58(c)(1)-3.)
Although the Bureau believes that issuers will generally find that emailing agreement links or
webpage addresses to the Bureau is the fastest and simplest way to submit the required
agreements, you may also comply by emailing us pdf copies of all the agreements you offered to
the public as of the end of December 2017. Alternatively, you may email us the agreements and
information identified in § 1026.58(c)(1)(ii), (iii), and (iv). Whatever submission method you
choose, remember to include your identifying information.
Do not encrypt or password-protect your email submission. The information you
are submitting is already public.
consumerfinance.gov
Where do I submit?
Send your submission to CardAgreements@consumerfinance.gov. We will email you a
confirmation of receipt within 2 business days.
When do I submit?
Your submitting email is due on or before January 31, 2018. This deadline applies to
agreements offered to new customers on December 31, 2017.
On an ongoing indefinite basis, quarterly submissions must be sent to the Bureau no later than
the first business day on or after January 31, April 30, July 31, and October 31 of each year. For
example, the quarterly submission deadlines for the next four quarters are:
•
January 31, 2018 (deadline applies to agreements offered on December 31, 2017);
•
April 30, 2018 (deadline applies to agreements offered on March 31, 2018); and
•
July 31, 2018 (deadline applies to agreements offered on June 30, 2018).
•
October 31, 2018 (deadline applies to agreements offered on September 30, 2018);
We will not be sending quarterly reminder emails in the future, so please take note of the
deadlines above.
Other questions?
If I submitted my credit card agreements to the Bureau in October 2017, and none of those
agreements have changed since then, do I still need to send agreements to the Bureau by
January 31?
No. If all the agreements you submitted to us last quarter have remained exactly the same
through the end of December, then you do not need to send us those agreements again.
Are there exceptions to the submission requirements for small issuers?
Yes. The “de minimis” exception is outlined in § 1026.58(c)(5) and may apply to you if you
maintain a very small number of credit card accounts. Please refer to it and email us if you
have any questions about whether you may be exempt from the submission requirement.
What if some of my private label agreements are not posted on my own website but only on
the website of my merchant partner?
If you have some agreements for which you comply with § 1026.58(d)(1) by posting the
agreement only on the merchant partner’s website, then your email should include links or
consumerfinance.gov
webpages for the agreements on that merchant’s website.
What if I revise the list of agreements on my website after the end of December 2017 but
before I send my submitting email to the Bureau?
Do not send links or webpage addresses that are inoperable at the point that you send them.
Instead, you can send in links or webpages after the end of December but before you make your
revisions OR you can attach to your email pdf copies of the agreements as they were prior to
those revisions.
What if the posted agreements or my identifying information change after I send my
submitting email to the Bureau?
Regulation Z requires submissions to be made on a quarterly basis. Therefore, you will be
required to include these changes in your next submission.
The Bureau used to send me a submitting spreadsheet, on which I had to report whether older
agreements had been revised, or dropped, or were still in force. Are you still using that
spreadsheet?
No. We have dropped the use of that spreadsheet in favor of the more streamlined submission
method of sending links or webpage addresses.
Will you still send reminder notices to submit my agreements in the future?
No. Since this submission process is an ongoing requirement, we will not be sending reminder
notices.
I still have questions…
Please email CardAgreements@consumerfinance.gov.
Paperwork Reduction Act
According to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person
is not required to respond to a collection of information unless it displays a valid OMB control number.
The OMB control number for this collection is 3170-0052. It expires on XX/XX/XXXX. The time required
to complete this information collection is estimated to average approximately 15 minutes per response.
The obligation to respond to this collection of information is mandatory. (12 CFR § 1026.57(d); and 15
U.S.C. § 1637(r)). Comments regarding this collection of information, including the estimated response
time, suggestions for improving the usefulness of the information, or suggestions for reducing the burden
to respond to this collection should be submitted to Bureau at the Consumer Financial Protection Bureau
(Attention: PRA Office), 1700 G Street NW, Washington, DC 20552, or by email to
CFPB_PRA@Consumerfinance.gov.
consumerfinance.gov
File Type | application/pdf |
Author | Sietse Goffard |
File Modified | 2018-07-06 |
File Created | 2017-12-12 |