As part of an effort to modernize and streamline certain submission practices for credit card issuers, the Consumer Finance Protection Bureau (“CFPB”) now requires credit card issuers to submit certain reporting requirements in under the Truth in Lending Act (“TILA”) and the Credit Card Accountability Responsibility and Disclosure Act (“CARD Act”) to the agency’s existing online and interactive platform called Collect. With reference to the applicable rules, please refer to 12 CFR § 1026.58.
In 2018, the CFPB offered some credit card issuers the option of submitting voluntarily online with Collect. Now, as of August 23, 2021, certain submissions under TILA and the CARD Act to Collect are mandatory.
Under TILA, credit card issuers, from time to time and randomly selected, are required to participate in the Credit Card Plans Terms Survey (“TCCP Survey”). Under the new guidelines, selected credit card issuers participating in the TCCP survey cycle starting January 31, 2022 will be the first cohort to submit through Collect by February 14, 2022.
In addition, in accordance with CARD and TILA, CFPB now requires that quarterly credit card agreement submissions, in accordance with CARD, be submitted through Collect from the fourth quarter of the calendar year. 2021 of credit card issuers.
Finally, under both laws, credit card issuers are required to submit annual reports regarding college credit card marketing agreements and certain data. Credit card issuers must now submit via Collect no later than March 31, 2022 for agreements and documents entered into in calendar year 2021.
Quarterly Credit Card Agreement and Annual College Credit Card Marketing Agreement Submissions must be in searchable PDF format and digitally created; in other words, “image only” scanned PDF files are not acceptable.
To register for Collect, please visit the following link here.