ARLINGTON, Va.—Quarterly credit card agreements are due to the CFPB April 30 in accordance with the Truth in Lending Act (TILA).
The rule applies unless the credit card agreement previously submitted continues to be offered and has not been amended. In addition, the rule has exceptions for certain private label cards and for credit unions with fewer than 10,000 open credit card accounts, NAFCU noted.
Last year, the CFPB suspended this requirement as part of its pandemic-related relief but rescinded this suspension – along with many other policy statements – in March. In the bulletin rescinding this regulatory flexibility, the Bureau indicated that credit unions subject to the rule will be required to submit credit card agreements for both the first quarter of 2021, and all four quarters of 2020, CUNA noted.
What’s Required
Credit card agreements must contain the following information when submitted to the Bureau:
- Identifying information about the credit union, including its name, address and identifying number (such as its tax identification number)
- The credit card agreements offered by the credit union as of the last business day of the preceding calendar quarter that it has not already submitted to the Bureau
- Any card agreement previously submitted to the Bureau that was amended during the preceding calendar quarter
- Notification regarding any previously agreement submitted to the Bureau that the credit union is now withdrawing