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Annual College Credit Card Agreement Submission FAQs

The questions and answers below pertain to compliance with the Bureau’s Annual College Credit Card Agreement Submission.

This is a Compliance Aid issued by the Consumer Financial Protection Bureau. The Bureau published a Policy Statement on Compliance Aids, available here, that explains the Bureau’s approach to Compliance Aids.

Topics

General FAQs

The Truth in Lending Act, 15 U.S.C. 1637(r) (also known as TILA section 127(r)), and Regulation Z, 12 CFR 1026.57(d), require that any card issuer that was a party to one or more college credit card marketing agreements in effect at any time during a calendar year submit to the CFPB an annual report regarding those agreements.

The term “college credit card agreement” means any business, marketing or promotional agreement between a card issuer and an institution of higher education or an affiliated organization in connection with which college student credit cards are issued to college students currently enrolled at that institution. 12 CFR 1026.57(a)(5).

Business, marketing or promotional agreements may include a broad range of arrangements between a card issuer and an institution of higher education or affiliated organization, including arrangements that do not meet the criteria to be considered college affinity card agreements as discussed in TILA section 127(r)(1)(A). For example, TILA section 127(r)(1)(A) specifies that under a college affinity card agreement, the card issuer has agreed to make a donation to the institution or affiliated organization, the card issuer has agreed to offer discounted terms to the consumer, or the credit card will display pictures, symbols, or words identified with the institution or affiliated organization; even if these conditions are not met, an agreement may qualify as a college credit card agreement, if the agreement is a business, marketing or promotional agreement that contemplates the issuance of college student credit cards to college students currently enrolled (either full-time or part-time) at the institution. An agreement may also qualify as a college credit card agreement even if marketing of cards under the agreement is targeted at alumni, faculty, staff, and other non-student consumers, as long as cards may also be issued to students in connection with the agreement. Comment 57(a)(5)-1.

The term “college credit card agreement” also includes a business, marketing, or promotional agreement between a card issuer and a college or university (or an affiliated organization, such as an alumni club or a foundation) if the agreement provides for the addition of a covered separate credit feature that is a credit card account under an open-end (not home-secured) consumer credit plan accessible by a hybrid prepaid-credit card as defined by 12 CFR 1026.61 to prepaid accounts previously issued to full-time or part-time students. This definition also includes a business, marketing, or promotional agreement between a card issuer and a college or university (or an affiliated organization, such as an alumni club or a foundation) if (1) the agreement provides for the issuance of prepaid accounts as defined in § 1026.61 to full-time or part-time students; and (2) a covered separate credit feature that is a credit card account under an open-end (not home-secured) consumer credit plan accessible by a hybrid prepaid-credit card as defined by § 1026.61 may be added in the future to the prepaid account. Comment 57(a)(5)-1.

Updated February 28, 2022

A card issuer must submit its annual report for each calendar year to the CFPB by the first business day on or after March 31 of the following calendar year. 12 CFR 1026.57(d)(3). For example, a card issuer must submit its annual report for calendar year 2022 to the CFPB by Friday, March 31, 2023.

Updated February 28, 2022

The financial institution must include the new college credit card agreement in its next annual report, which would need to be submitted to the CFPB be no later than the first business day on or after March 31 of the following calendar year. See 12 CFR 1026.57(d)(3). For example, if your institution entered into the agreement on December 31, 2022, your institution would include that agreement in its annual report for calendar year 2022, which must be submitted to the CFPB by Friday, March 31, 2023.

Updated February 28, 2022

Yes, a card issuer that was a party to one or more college credit card agreements in effect at any time during a calendar year must submit to the Bureau an annual report regarding those agreements, even if you previously submitted the agreement to the CFPB and even if the agreement has not changed. See 12 CFR 1026.57(d).

Updated February 28, 2022

A card issuer must submit an annual report to the CFPB that contains the information listed in 12 CFR 1026.57(d)(2). The information in the annual report includes:

  • Identifying information about the card issuer and the agreements submitted, including the issuer's name, address, and identifying number (such as an RSSD ID number or tax identification number);
  • A copy of any college credit card agreement to which the card issuer was a party that was in effect at any time during the period covered by the report;
  • A copy of any memorandum of understanding in effect at any time during the period covered by the report between the card issuer and an institution of higher education or affiliated organization that directly or indirectly relates to the college credit card agreement or that controls or directs any obligations or distribution of benefits between any such entities;
  • The total dollar amount of any payments pursuant to a college credit card agreement from the card issuer to an institution of higher education or affiliated organization during the period covered by the report, and the method or formula used to determine such amounts;
  • The total number of credit card accounts opened pursuant to any college credit card agreement during the period covered by the report; and
  • The total number of credit card accounts opened pursuant to any such agreement that were open at the end of the period covered by the report.

This information must be submitted to the CFPB using Collect. For more information on submitting this information to the CFPB, please review the FAQs below and the CFPB’s College Credit Card Agreements website.

Updated February 28, 2022

A memorandum of understanding includes any document that amends the college credit card agreement, or that constitutes a further agreement between the parties as to the interpretation or administration of the agreement. For example, a memorandum of understanding required to be included in the report would include a document that provides details on the dollar amounts of payments from the card issuer to the university, to supplement the original agreement which only provided for payments in general terms (e.g., as a percentage). A memorandum of understanding for these purposes would not include email (or other) messages that merely discuss matters such as the addresses to which payments should be sent or the names of contact persons for carrying out the agreement. Comment 57(d)(2)-1.

Updated February 28, 2022

Yes. Card issuers may submit agreements with other types of organizations that provide for the issuance of credit cards to students, but card issuers are not required to do so. Card issuers are only required to submit agreements with an institution of higher education or affiliated organization as defined by §1026.57(a)(3) and (4).

When submitting an agreement for an organization that is not an institution of higher education or affiliated organization, select “other” under institution type. Page 8 of the College Credit Card Marketing Agreement User Guide provides additional information that will assist you in reporting this type of agreement.

Updated February 28, 2022

Submitting Annual College Credit Card Agreement Submission FAQs

An institution must submit its annual report using the CFPB’s Collect website. Collect will guide you through the submission process. The CFPB has created an annual college credit card agreement submission quick reference guide and user guide that explain how an institution can make a submission using Collect. These guides can be accessed on the CFPB’s website.

Updated February 28, 2022

To register your institution to submit quarterly credit card agreements through Collect, please complete the Collect Registration Form and submit it to Collect_Support@cfpb.gov. After the CFPB processes the Collect Registration Form, the point of contact (POC) listed on the Collect Registration Form can either make College Credit Card Marketing Agreement submissions or delegate another person (delegated POC) to make College Credit Card Marketing Agreement submissions.

Updated February 28, 2022

A POC is an individual at your institution who can delegate to other people at your institution permission to submit information via Collect (delegated POCs). The POC also has the ability to remove these permissions, if desired. If you are unsure who your institution’s POC is, contact Collect_Support@cfpb.gov.

Updated February 28, 2022

Yes. All data submitted by your institution is viewable by you and any delegated POCs in Collect. Once your data is submitted, the CFPB will review and publish the data at https://www.consumerfinance.gov/data-research/student-banking/.

Updated February 28, 2022

Yes, but issuers will not be able to edit the annual report once data and the associated documents are submitted. To correct the error, please contact Collect_Support@cfpb.gov.

Updated February 28, 2022

Pursuant to the Technical Specifications for Credit Card Agreement and Data Submissions Required under TILA and the CARD Act (Regulation Z) Procedural Rule issued on August 20, 2021, the CFPB no longer accepts annual college credit card agreement submissions through email. Thus, card issuers must use Collect to submit their annual college credit card agreements to the CFPB for college credit card agreements in 2021, for which submissions are due on March 31, 2022.

Updated February 28, 2022

Collect Website FAQs

Yes. Please email Collect_Support@cfpb.gov to request your user login information or to unlock your account. The CFPB’s support team will contact you to verify your identity and provide you with access to your account.

Updated February 28, 2022

Yes. Please email all questions to Collect_Support@cfpb.gov. The CFPB’s support team will ensure that you receive a timely response.

Updated February 28, 2022