CFPB headquarters in Washington, D.C. (Source: Shutterstock)
Banks and credit unions that are required to send information to the Consumer Protection Bureau for credit card terms and agreements, will soon be required to use the CFPB's "Collect" website starting next year.
The CFPB published the rule in the Federal Register on Aug. 23, but some of the deadlines for registering for the new system are approaching in just a few weeks.
The Collect system has been around since 2018 and is designed to make submissions easier to file, harder to mess up and provide an audited trail to verify that information was sent. It was specifically developed for the Terms of Credit Card Plans (TCCP) Survey, which the CFPB is required by law to use to gather pricing and availability information from at least 150 issuers twice a year.
The group includes the top 25 issuers based on outstanding balances. One of them is Navy Federal Credit Union of Vienna, Va. ($147.9 billion in assets, 10.6 million members), which had $19.8 billion in credit card balances as of June 30.
In addition, the CFPB must collect information from at least 125 other financial institutions from a broad sample it designs to ensure a fair geographic distribution and a wide spectrum of institutions. Only banks and credit unions contacted by the CFPB are required to file the survey.
About 83% of TCCP filers used the Collect system in filings that were due in January 2021, according to the CFPB's rule. The others use the FR 2572 Excel spreadsheet form born 31 years ago. Beginning next year, all TCCP filers will be required to use the Collect system.
Other CFPB filers will also have to use Collect starting in 2022, abandoning a hodgepodge of collection methods that includes emails of PDFs and website links for college credit card issuers, and for most issuers, who are required to submit quarterly updates on their credit card agreements.
The CFPB cited several advantages of the Collect system for filers:
- Instructions in Collect are "tiered" so that the submitter only sees relevant questions, reducing the chances for confusion or error.
- Collect also avoids asking submitters for the same information twice.
- Collect provides an audit trail that allows issuers to verify whether and when each of their submissions has been received by the Bureau and review the contents of past submissions.
- The CFPB said it has heard through its market outreach efforts that TCCP survey respondents "find Collect to be faster to use than the FR 2572 form, and that it allows them to more easily reference past submissions."
As for the agency, the CFPB said Collect allows faster processing of TCCP Survey submissions by CFPB staff, "which in turn has led to the faster posting of the TCCP Survey results on the Bureau's website and enhanced the public's ability to use the data in a timely manner."
All issuers required to make quarterly credit card agreement submissions to the CFPB must register for Collect by Nov. 1, 2021. Once the issuer receives its login credentials, the issuer will have the ability to review its current submissions and start making the required submissions using Collect Dec. 1.
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