On September 30, the CFPB published a notice seeking comment on a proposed revision to its existing collection of credit card information under the Truth in Lending Act (TILA) and the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act). The notice addresses three existing credit card reporting requirements administered by the CFPB. Specifically, the Bureau is seeking approval to revise its collection of:
- Credit card pricing and availability information. Through the Terms of Credit Card Plans Survey, the CFPB collects pricing and availability data from a broad sample of at least 150 issuers, including the 25 largest credit card issuers and at least 125 additional financial institutions.
- Consumer credit card agreements. The CFPB collects quarterly submissions of consumer credit card agreements from issuers with 10,000 or more open credit card accounts, as required under the CARD Act and Regulation Z.
- College credit card agreements and related information. The CFPB collects annual submissions of college credit card agreements and certain information concerning arrangements between card issuers and institutions of higher education.
According to the notice, these collections support a centralized and searchable repository of credit card terms, consumer and college credit card agreements, and related information. The Bureau is seeking comment on the necessity and practical utility of the collections, potential improvements to the information collected, and opportunities to reduce reporting burdens through automation or other technology. Comments are due October 30, 2026.
Putting It Into Practice: Although the notice does not change the underlying credit card reporting requirements, it gives issuers an opportunity to raise operational concerns with the CFPB’s existing collection processes and burden estimates. Issuers subject to these reporting requirements should review their current submission processes and consider whether changes to the collection framework or reporting mechanics would reduce compliance burdens or improve the usefulness of submitted data.
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