Alert puts credit unions on notice: submissions to CFPB’s ‘Collect’ website can be made now (and note those deadlines)

Credit unions may begin submitting data on credit card agreements with their members, and applying data submission requirements, to the federal consumer financial protection agency’s website for collecting credit card information, the National Credit Union Administration (NCUA) said Wednesday.

In a “regulatory alert,” the NCUA said the credit unions may begin submitting data to the Consumer Financial Protection Bureau’s (CFPB) “Collect” website using submission deadline dates of:

  • Feb. 14, 2022, for terms of credit card plans (TCCP) survey data;
  • Jan. 31, 2022, for quarterly credit card agreement submissions;
  • March 31, 2022, for annual reports related to college credit card marketing agreements and data.

On Aug. 20, the consumer bureau issued new technical specifications for complying with credit card agreement and data submission requirements under the Truth in Lending Act (TILA) and the Credit Card Accountability Responsibility and Disclosure (CARD) Act of 2009. In the specifications, the bureau said all submissions would be made via the agency’s Collect website beginning in January.

The Collect website has been available since July 2018 for those participating in the semiannual TCCP Survey. According to the bureau, 83% of survey submissions early this year were made via Collect.

The credit card plan submissions are made by selected card issuers under requirements of the TILA and the CARD Act. Submissions include the semiannual TCCP Survey, quarterly credit card agreements, and annual reports related to college credit card marketing agreements and data.

Issuers have until Nov. 1 of this year to register for Collect; those that have registered before to submit their TCCP Survey data will not need to register again.

To register, the bureau said, issuers should fill out and email the Collect registration form to Collect_Support@cfpb.gov. Those selected to participate in the TCCP Survey or which are required to submit an annual report could start registering Aug. 20.

Once card issuers receive their login credentials, starting on Dec. 1, 2021, they will be able to review their current submissions and make the required submissions for the fourth quarter of calendar year 2021 using Collect, the CFPB said.

The NCUA reminded that credit unions selected to participate in the TCCP Survey or are required to submit an annual report of college student credit card agreements can register now. 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, the credit union regulator said, and must register for Collect by Nov. 1, 2021.

“Once a credit union receives its login credentials, it will be able to review its current submissions and make the required submissions for the fourth quarter of calendar year 2021 starting on Dec. 1, 2021,” the NCUA said.

NCUA Regulatory Alert 21-RA-09: CFPB Issues New Specifications for its Collect Website Relating to Credit Card Data Submission

Technical Specifications for Credit Card Agreement and Data Submissions Required under TILA and the CARD Act (Regulation Z)

 

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