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The CFPB proposed revisions to its long-standing credit card data collection program that could significantly expand the number of banks and credit unions subject to federal surveys, according to a new filing published in the Federal Register.
Under the proposal, the CFPB would revise its information collection for the Report of Terms of Credit Card Plans (Form FR 2572) and required submissions of consumer and college credit card agreements. The changes would be administrative in nature and fall under the Paperwork Reduction Act, but they would carry notable implications for smaller card issuers.
Beginning with the January–June 2025 survey cycle, the CFPB expanded its sampling universe from roughly 700 credit card issuers to about 2,200 banks and credit unions with at least $1 million in credit card balances, based on Call Report data. The Bureau also adopted a stratified random sampling approach, citing alignment with the Trump administration's "Restoring Gold Standard Science" executive order.
Previously, CFPB credit card surveys focused largely on issuers with 10,000 or more open accounts, many of which were already required to submit card agreements through the agency's Collect system. The revised approach would increase the likelihood that smaller credit unions and community banks could be selected to participate.
The CFPB is also seeking comment on potential future changes, including whether to weight survey selection by portfolio size or increase the number of participating institutions from 225 to as many as 450 annually. The Bureau acknowledged that such changes could raise compliance burdens and said it may revise its official burden estimates.
The filing leaves intact existing requirements for quarterly consumer credit card agreement submissions and annual college card agreement reporting. Public comments on the proposal are due within 60 days of publication.
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