America's Credit Unions called on the Consumer Financial Protection Bureau to refine its credit card data collection process, arguing that current reporting requirements place unnecessary burdens on financial institutions, particularly smaller credit unions.
Responding to the CFPB's Paperwork Reduction Act review of its credit card agreement survey, the organization proposed several changes aimed at improving efficiency while maintaining transparency, in a comment letter.
James Akin, head of regulatory advocacy, said the existing reporting framework requires significant staff time and manual data entry, often involving the submission of agreements that provide limited analytical value.
Among the recommendations is a shift to a "change-only" reporting model, which would allow institutions to submit updates only when terms have changed, rather than resubmitting full agreements each cycle. Credit unions would instead provide an attestation confirming that unchanged terms remain accurate.
The group also urged the CFPB to refine criteria determining which credit card agreements must be submitted, ensuring the agency receives the most relevant data while reducing duplicative filings.
"A more targeted set of submission requirements would help ensure that the CFPB receives the agreements that are most relevant," Akin said.
America's Credit Unions emphasized that credit unions remain committed to offering competitive rates and transparent terms, and that improvements to the reporting process would better align regulatory objectives with operational realities.
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