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Statement on Supervisory and Enforcement Practices Regarding Bureau Information Collections for Credit Card and Prepaid Account Issuers

The Bureau recognizes the impact that the COVID-19 pandemic is having on consumers and many supervised entities. The Bureau is therefore issuing this policy statement in order to provide firms with more flexibility and reduce burden on credit card and prepaid account issuers, allowing them to focus their time and attention on making sure consumers continue to have access to credit and other funds.

As of March 26, 2020, and until further notice, the Bureau does not intend to cite in an examination or initiate an enforcement action against any entity for failure to submit to the Bureau the following information relating to credit card and prepaid accounts:

  • Annual submission of certain information concerning agreements between credit card issuers and institutions of higher education (and certain affiliated organizations), as required by the Truth in Lending Act (TILA), 15 U.S.C. § 1637(r), and Regulation Z, 12 CFR 1026.57(d)(3);
  • Quarterly submission of consumer credit card agreements, as required by TILA, 15 U.S.C. § 1632(d)(2), and Regulation Z, 12 CFR 1026.58(c);
  • Collection of certain credit card price and availability information from a sample of credit card issuers under TILA, 15 USC §1646(b)(1) et seq.; and
  • Submission of prepaid account agreements and related information required by Regulation E, 12 CFR 1005.19(b).

At a later date, the Bureau will notify entities of when and how to submit information under these requirements. Entities should maintain records sufficient to allow them to make such delayed submissions pursuant to Bureau guidance.


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