NCUA Alert: CFPB’s New Technical Specifications Relating to Credit Card Data Submission

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The National Credit Union Administration (NCUA) issued a regulatory alert this week notifying federally insured credit unions of the Consumer Financial Protection Bureau’s (CFPB) 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 Act of 2009 (CARD Act).

In August 2021, the CFPB established a new system, “Collect” as the mandatory vehicle for credit card agreement and data submissions. 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 pursuant to 12 CFR 1026.58(c).  Credit unions are not required to submit any credit card agreements to the CFPB if the credit union had fewer than 10,000 open credit card accounts as of the last business day of the calendar quarter.

Credit unions can begin submitting the following data to the CFPB using Collect, starting with listed submission dates:

  • Terms of Credit Card Plans (TCCP) Survey data (for the Feb.14, 2022, deadline);
  • Quarterly credit card agreement submissions (for the Jan. 31, 2022, deadline); and
  • Annual reports related to college credit card marketing agreements and data (for the March 31, 2022, deadline).

Credit unions need to register for the “Collect” system by completing the CFPB’s form and submitting it to collect_support@cfpb.gov by Nov. 1, 2021

Credit unions that are selected to participate in the TCCP Survey or are required to submit an annual report of college student credit card agreements pursuant to 12 CFR 1026.57(d) may register now. 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. For more details, view the technical specifications for the system on the CFPB’s website.

The regulatory alert notes that the CFPB is in the process of updating and publishing resources to help card issuers use Collect. The CFPB will continue to publish resources for the quarterly credit card agreement submissions and annual reports related to college credit card marketing agreements and data online.

To view the NCUA’s regulatory alert in its entirety, see here.

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