Banks and credit unions that are required to send information to the Consumer Protection Bureau for credit card terms and agreements, will soon be required to use CFPB’s “Collect” website from next year.
CFPB published the rule in the Federal Register on August 23, but some of the application deadlines for the new system are approaching in a few weeks.
The Collect system has been around since 2018 and is designed to make submissions easier to file, harder to mess up, and provide an audited trail to verify that information has been sent. It was specially developed for the Credit Card Plan Conditions Survey (TCCP), which the CFPB is required by law to use to collect information on pricing and availability from at least 150 issuers two times a year.
The group comprises the top 25 issuers on the basis of outstanding balances. One of them is the Navy Federal Credit Union in Vienna, Virginia ($ 147.9 billion in assets, 10.6 million members), which had $ 19.8 billion in credit card balances. credit as of June 30.
In addition, the CFPB should collect information from at least 125 other financial institutions from a large sample it designs in order to ensure equitable geographic distribution and a wide range of institutions. Only banks and credit unions contacted by the CFPB are required to complete the questionnaire.
About 83% of TCCP filers used the Collect system in deposits due to be deposited in January 2021, according to the CFPB rule. The others use the Excel FR 2572 spreadsheet which was born 31 years ago. Starting next year, all TCCP registrants will be required to use the Collect system.
Other CFPB depositors will also have to use Collect from 2022, ditching a mishmash of collection methods that includes PDF file emails and links to websites for college credit card issuers and for the Most issuers, who are required to submit quarterly updates on their credit card agreements. .
CFPB cited several advantages of the Collect system for declarants:
- The statements in Collect are “prioritized” so that the requester sees only the relevant questions, reducing the likelihood of confusion or error.
- Collect also avoids asking authors twice for the same information.
- Collect provides an audit trail that allows issuers to verify if and when each of their submissions has been received by the Bureau and to review the content of past submissions.
- The CFPB said it heard, through its market outreach efforts, that respondents to the TCCP survey âfound that Collect is faster to use than the FR 2572 form, and that it allows them to reference more easily. previous submissions â.
Regarding the agency, CFPB says Collect allows for faster processing of TCCP survey submissions by CFPB staff, “which in turn led to faster publication of TCCP survey results on the website. office and improved the public’s ability to use data in a timely manner. manner.”
All issuers required to submit quarterly credit card agreements to CFPB must register with Collect by November 1, 2021. Once the issuer receives their login credentials, the issuer will have the opportunity to review their credentials. current submissions and start making the required submissions using Collect on December 1st.