Skip to content
BOL Conferences
Thread Options
#1816330 - 05/21/13 10:48 PM Credit Card Agreements to the CFPB
Jan94 Offline
Platinum Poster
Joined: Mar 2001
Posts: 828
USA
I need some help in understanding the following Reg Z requirement.

This is from Subpart G—Special Rules Applicable to Credit Card Accounts and Open-End Credit Offered to College Students

§ 1026.58 Internet posting of credit card agreements.
(a) Applicability. The requirements of this section apply to any card issuer that issues credit cards under a credit card account under an open-end (not home-secured) consumer credit plan.

(b) Definitions. (1) Agreement. For purposes of this section, “agreement” or “credit card agreement” means the written document or documents evidencing the terms of the legal obligation, or the prospective legal obligation, between a card issuer and a consumer for a credit card account under an open-end (not home-secured) consumer credit plan. “Agreement” or “credit card agreement” also includes the pricing information, as defined in §1026.58(b)(7).


In (c) it provides for the reporting of agreements (as defined above) to the CFPB on a quarterly basis:

(c) Submission of agreements to Bureau. (1) Quarterly submissions. A card issuer must make quarterly submissions to the Bureau, in the form and manner specified by the Bureau. 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. Each submission must contain:

(i) Identifying information about the card issuer and the agreements submitted, including the issuer's name, address, and identifying number (such as an RSSD ID number or tax identification number);

(ii) The credit card agreements that the card issuer offered to the public as of the last business day of the preceding calendar quarter that the card issuer has not previously submitted to the Bureau;

(iii) Any credit card agreement previously submitted to the Bureau that was amended during the preceding calendar quarter and that the card issuer offered to the public as of the last business day of the preceding calendar quarter, as described in §1026.58(c)(3); and

(iv) Notification regarding any credit card agreement previously submitted to the Bureau that the issuer is withdrawing, as described in §1026.58(c)(4), (c)(5), (c)(6), and (c)(7).


What exactly is this asking for? Is it saying that we are supposed to send copies of the credit card agreements we provide to our customers and our pricing information to the CFPB? Is this only if we post our agreement on the website? What does the CFPB do with this information?

Thank you!

Return to Top
Lending Compliance
#1816372 - 05/22/13 01:32 PM Re: Credit Card Agreements to the CFPB Jan94
swiggles Offline
Power Poster
swiggles
Joined: Aug 2001
Posts: 7,351
My former bank fell under the de minimis exception, so all we had to do was post the agreement (there was only one) on our website.

(5) De minimis exception. (i) A card issuer is not required to submit any credit card agreements to the Bureau if the card issuer had fewer than 10,000 open credit card accounts as of the last business day of the calendar quarter.

I don't know what the cfpb does with the info.
_________________________
The more you sweat in training, the less you bleed in battle.......

Return to Top
#1816548 - 05/22/13 06:22 PM Re: Credit Card Agreements to the CFPB Jan94
Jan94 Offline
Platinum Poster
Joined: Mar 2001
Posts: 828
USA
Thank you! I was just trying to be sure I actually understood this--not sure I do. Our bank would not be able to fall under the de minimus exception so is it that straight forward that it is saying we have to send copies of our agreements (and pricing) to the CFPB? If they are not posted on our website, do we still have to send them? Or is it if they are already possted on the website? I'm just concerned that I completely missed this if we are supposed to send them.

Return to Top
#1816553 - 05/22/13 06:32 PM Re: Credit Card Agreements to the CFPB Jan94
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
If memory serves me, it's any written agreement, so any credit card plans you have would apply.

What do they do with it? I think it's so consumers can easily compare different large creditors products in one easy place.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top

Moderator:  Andy_Z