The CFPB posting is all about the card issuer and the credit card agreement. The card issuer is the entity to which the consumer is legally obligated under the terms of the agreement.
If your bank is the issuer, you have the responsibility of compliance with § 1026.58. You can outsource to a third party the submission of the agreement to the CFPB, but you can't outsource the responsibility for filing it.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8