WASHINGTON–In a position seldom taken, CUNA has told the Bureau of Consumer Financial Protection that the reg burden around one requirement isn’t that bad and it should remain in place.
CUNA sent a letter to the BCFP regarding its request to the Office of Management and Budget (OMB) to allow the Bureau to continue collecting certain documents from credit card issuers for public disclosure on the their website. Specifically, card issuers must submit to the Bureau: (1) agreements between the issuer and consumer for a consumer credit card account; and (2) any college credit card agreements to which the issuer is a party and certain additional information regarding those agreements.
In its letter, CUNA said, “While at first very onerous, since credit unions have been complying with these requirements for the better part of the past decade, the compliance burden has declined. We acknowledge the benefit to consumers of being able to easily access the Bureau’s website to review and compare credit card agreements across all issuers. To ensure agreements are submitted on a timely basis, we ask the CFPB to send quarterly reminders to card issuers.”
CUNA added that while the Bureau’s request for comment focuses on the collection of credit card agreements, it used the letter as an “opportunity to reiterate concerns regarding credit card disclosures.”
CUNA said it is encouraging the Bureau to explore the overall effectiveness of credit card disclosures, as well as ways in which disclosures, including those mandated by the CARD Act, that can be simplified.
“The CFPB has acknowledged, and the association agrees, that overly complex disclosures are less effective in informing consumers about the terms of a financial product,” CUNA said.
The letter further requests that the CFPB continue to look for ways to improve disclosures as they relate not only to the consumer but also to affected financial institutions.