CUs on notice: start submitting card data to CFPB

(Oct. 1, 2021) Credit unions may begin submitting data on credit card agreements with their members, and applying data submission requirements, to the CFPB’s website for collecting credit card information, NCUA said this week.

In a “regulatory alert,” the agency said credit unions may begin submitting data to the bureau’s “Collect” website using submission deadline dates of:

  • Feb. 14, 2022, for terms of credit card plans (TCCP) survey data;
  • Jan. 31, 2022, for quarterly credit card agreement submissions;
  • March 31, 2022, for annual reports related to college credit card marketing agreements and data.

On Aug. 20, the consumer bureau issued new technical specifications for complying with credit card agreement and data submission requirements under the Truth in Lending Act (TILA) and the Credit Card Accountability Responsibility and Disclosure (CARD) Act of 2009. In the specifications, the bureau said all submissions would be made via the agency’s Collect website beginning in January.

The Collect website has been available since July 2018 for those participating in the semiannual TCCP Survey. According to the bureau, 83% of survey submissions early this year were made via Collect.

NCUA, in the letter, reminded that credit unions selected to participate in the TCCP Survey or are required to submit an annual report of college student credit card agreements can register now. Any credit union with 10,000 or more credit card accounts as of any quarter-end is required to make quarterly credit card submissions to the CFPB, the credit union regulator said, and must register for Collect by Nov. 1, 2021.

“Once a credit union receives its login credentials, it will be able to review its current submissions and make the required submissions for the fourth quarter of calendar year 2021 starting on Dec. 1, 2021,” NCUA said.


NCUA Regulatory Alert 21-RA-09: CFPB Issues New Specifications for its Collect Website Relating to Credit Card Data Submission

Technical Specifications for Credit Card Agreement and Data Submissions Required under TILA and the CARD Act (Regulation Z)