The NCUA issued a regulatory alert to credit unions on Wednesday about the CFPB’s new technical specifications for complying with credit card agreement and data submission requirements under the Truth in Lending Act and the Credit Card Accountability Responsibility and Disclosure Act of 2009.
To comply with these laws, credit unions with applicable credit card portfolios will need to make the required submissions through the CFPB’s Collect website. 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) and must register for Collect by Nov. 1, 2021.
Credit unions can begin submitting the following data to the CFPB starting with the following submission dates, according to the NCUA:
- terms of credit card plans 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).
Prior to using the Collect website, credit unions will need to complete the Collect registration form. Credit unions that previously registered do not need to register again.