Fewer colleges are sponsoring credit card programs these days,and those that do are likely breaking the law when it comes todisclosures, according to the CFPB's sixth annual report oncollege credit card agreements.

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The study of 369 college credit card agreements from 33 issuersfound there were 65% fewer sponsored programs in 2014 versus in 2009, and theoverall number of school-affiliated credit card accounts opendropped by 58% between 2009 and 2014. The study also found issuerpayments to schools and affiliated organizations plummeted from$84.5 million in 2009 to just $34.1 million in 2014 – a decrease of60%. Between 2013 and 2014 alone, issuers paid 20% less topartners, the CFPB found.

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However, the number of new accounts opened per year was actually12% higher in 2014 than in 2009, according to the CFPB. One reason:Only about one quarter of agreements in 2014 were actually betweenissuers and schools, the CFPB said.

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“Nearly three-quarters of this new account growth … isconsistently accounted for by agreements between issuers and alumniassociations, indicating that most new accounts likely are issuedto alumni, not to students,” the CFPB noted.

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In fact, 55% of all college card agreements in 2014 were withalumni associations, 10% were with foundations and 11% were withother types of affiliated organizations, the study said.

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Large banks are retreating from the campus card market,however. Capital One exited it entirely in 2014, according to theCFPB. And Bank of America, the long-time dominant player in themarket, ended about 100 agreements in 2013 and another 26 in 2014,making 2014 the first year in which it had fewer than half (125) ofall total agreements. However, that bank still represents nearly80% of all accounts open under campus card agreements.

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Now, credit unions appear to be filling part of the void. Of the33 issuers in the 2014 study, 20 were credit unions, the reportsaid.

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The West Lafayette, Ind.-based Purdue Federal Credit Union,which has $954 million in assets and 68,000 members, was thelargest issuer, with 25,341 open accounts in 2014. It made$1,000,000 in payments to the Purdue Alumni Association last year,according to the CFPB.

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The $2 billion Apple Federal Credit Union in Fairfax, Va.; the$1.9 billion Georgia's Own Credit Union in Atlanta; the $503million Harvard University Employees Credit Union in Cambridge,Mass.; the $4.8 billion Mountain America Federal Credit Union inWest Jordan, Utah; the $348 million The Southern Credit Union inFayetteville, Ga. and the $2 billion University of Wisconsin CreditUnion in Madison, Wis. are among the newest issuers – they didn'tsubmit card agreements in 2013 but did so in 2014, the CFPB said.Harvard University Employees was the largest, netting 1,787accounts.

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Schools may not be doing all they can to ensure those agreements deter regulatory headaches,though.

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The CARD Act requires issuers to submit information about theircollege credit card accounts to the CFPB; colleges must alsopublicly disclose their agreements with issuers.

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“Under current rules, colleges are able to comply with thisrequirement by publishing any relevant credit card agreement ontheir website or by making it available free of charge upon requestusing reasonable procedures and in a reasonable timeframe,” itsaid.

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However, the CFPB found that of 25 schools sampled, 20 did notput their card agreements on their websites. And of that 20, onlythree provided them upon request. On Dec. 16, the CFPB sent warningletters to 17 colleges, directing them to beef up theirdisclosures.

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“The general failure to disclose the agreements conflicts withthe CARD Act's clear direction to colleges and thus may violatefederal law,” the report said.

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The CFPB noted its findings have certain limitations, however.Some college agreements cover other financial products, forexample, and not all who open accounts are students. In addition,data from card issuers excludes information about students who openaccounts in response to offers made to the general public ratherthan through the campus. And because issuers were required tosubmit all college credit card agreements to which they were aparty at any time during 2014, the information includes 97agreements no longer in effect – about one quarter of allagreements submitted, it said.

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In October, the Department of Education banned overdraft andswipe fees on student debit and prepaid cards. It also prohibitedschools from requiring students to open accounts with specificinstitutions in order to receive student aid funds.

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