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Credit Card Agreement Submission FAQs

The questions and answers below pertain to compliance Regulation Z’s Quarterly 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. 1632(d), and Regulation Z, 12 CFR 1026.58(c), require each card issuer to make quarterly submissions of its consumer credit card agreements to the Bureau when the card issuer (1) offers a new credit card agreement, (2) amends a credit card agreement, and (3) withdraws a credit card agreement. Card issuer, for the purposes of submitting credit card agreements, means an entity to which a consumer is legally obligated, or would be legally obligated, under the terms of a credit card agreement. 12 CFR 1026.58(b)(4). An issuer “offers” an agreement if the issuer is soliciting or accepting applications for accounts that would be subject to that agreement. 12 CFR 1026.58(b)(5). An issuer “amends” an agreement if it makes a substantive change to the agreement including any change in the pricing information. 12 CFR 1026.58(b)(2). An issuer “withdraws” an agreement if it no longer offers a credit card agreement to the public (i.e., no longer solicits or accepts applications for accounts that would be subject to that agreement) that has been previously submitted to the Bureau. 12 CFR 1026.58(c)(4).

Updated Nov. 19, 2021

Quarterly submissions to the Bureau must be made using Collect, the Bureau’s website used for submitting agreements, no later than the first business day on or after the following deadlines:

  • January 31 (deadline applies to agreements first offered, amended, or withdrawn between October 1 and December 31);
  • April 30 (deadline applies to agreements first offered, amended, or withdrawn between January 1 and March 31);
  • July 31 (deadline applies to agreements first offered, amended, or withdrawn between April 1 and June 30); and
  • October 31 (deadline applies to agreements first offered, amended, or withdrawn between July 1 and September 30).

See 12 CFR 1026.58(c)(1). For example, if a card issuer begins to offer a new credit card agreement between January 1 and March 31, it must submit that agreement to the Bureau by April 30 of that year, assuming no exceptions apply. Similarly, if between January 1 and March 31, an issuer amends a credit card agreement previously submitted to the Bureau, it must submit the amended agreement by April 30 of that year. If a card issuer withdraws a credit card agreement during that time period, it must notify the Bureau, using Collect, that it no longer offers to the public that agreement by April 30 of that year.

Updated Nov. 19, 2021

A card issuer is not required to make a quarterly submission to the Bureau if, during the previous calendar quarter, the card issuer did not (1) offer a new credit card agreement that was not submitted to the Bureau previously, (2) amend an agreement previously submitted to the Bureau, or (3) cease to offer an agreement previously submitted to the Bureau. See Comment 58(c)(1)-2 to Regulation Z, 12 CFR Part 1026.

Updated Nov. 19, 2021

Regulation Z, 12 CFR 1026.58(c)(5), contains a de minimis exception that exempts certain credit card issuers from making quarterly credit card submissions to the Bureau. To qualify for the de minimis exception, the card issuer must have fewer than 10,000 open credit card accounts as of the last business day of the calendar quarter. Once the card issuer has 10,000 or more open credit card accounts as of the last business day of the calendar quarter, it must begin making quarterly submissions. If a card issuer that did not previously qualify for the de minimis exception qualifies for the de minimis exception, the card issuer must continue to make quarterly submissions to the Bureau until the card issuer notifies the Bureau that the issuer is withdrawing all agreements it previously submitted to the Bureau. See Comment 58(c)(5)-5 to Regulation Z, 12 CFR Part 1026.

Updated Nov. 19, 2021

A financial institution must submit the credit card agreement, which is defined as the written document or documents evidencing the terms of the legal obligation, or the prospective legal obligation, between a card issuer and a consumer for a credit card account under an open-end (not home-secured) consumer credit plan. 12 CFR 1026.58(b)(1). The credit card agreement also includes the pricing information for the credit card plan. Pricing information must be set forth in a single addendum to the agreement. 12 CFR 1026.58(c)(8)(ii)(A). An issuer must submit only one pricing addendum with each agreement. Provisions of the agreement other than the pricing information that may vary from one cardholder to another depending on the cardholder's creditworthiness or state of residence or other factors, optionally may be set forth in a single addendum to the agreement separate from the pricing information addendum (i.e., in an optional variable terms addendum). 12 CFR 1026.58(c)(8)(iii).

Updated Nov. 19, 2021

Submitting Credit Card Agreement FAQs

A financial institution must submit, amend, or withdraw a credit card agreement using the Bureau’s Collect website. Collect will guide you through the submission, amendment, or withdrawal process. The Bureau has created a quarterly credit card agreement submission quick reference guide and user guide that explain how a financial institution can make a submission using Collect. These guides can be accessed on the Bureau’s website at www.consumerfinance.gov/data-research/credit-card-data/credit-card-agreement-submission.

Updated Nov. 19, 2021

To register your financial institution to make quarterly credit card agreements submissions through Collect, please complete the Collect Registration Form and submit it to Collect_Support@cfpb.gov. After the Bureau processes the Collect Registration Form, the Bureau’s Collect team will send a welcome email to the point of contact listed on the registration form. The welcome email will contain information about logging in to Collect.

Updated Nov. 19, 2021

A POC is an individual at your financial institution who can delegate to other people at your financial 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 financial institution’s POC is, contact Collect_Support@cfpb.gov.

Updated Nov. 19, 2021

Yes. All data submitted by your financial institution is viewable by you and any delegated POCs in Collect. Once your data is submitted, the Bureau will review and publish all final agreements at www.consumerfinance.gov/credit-cards/agreements/.

Updated Nov. 19, 2021

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 Bureau no longer accepts quarterly credit card agreement submissions via email. Card issuers must use Collect to submit their quarterly credit card agreements to the Bureau starting with the fourth quarter submissions in 2021, for which submissions are due on January 31, 2022. You can read the procedural rule at: www.consumerfinance.gov/rules-policy/final-rules/technical-specifications-for-credit-card-agreement-and-data-submissions-required-under-tila-and-the-card-act-regulation-z/.

Updated Nov. 19, 2021

Yes. To correct the error, please contact Collect_Support@cfpb.gov.

Updated Nov. 19, 2021

Collect Website FAQs

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

Updated Nov. 19, 2021

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

Updated Nov. 19, 2021