On February 19, the CFPB proposed a rule that would suspend the requirement that creditors submit agreements for open-end consumer credit plans to the Bureau under section 1632(d) of the Truth in Lending Act and section 1026.58 of Regulation Z. The temporary suspension would last one year, making it applicable to the next three quarterly submissions that were due in 2015 and the first quarterly submission due on January 31, 2015.
The purpose of this suspension is for the CFPB to develop “a more streamlined and automated electronic submission system” for issuers to submit credit card agreements to the CFPB in order to replace the current method of submission manually via email. Under the Credit Card Accountability Responsibility and Disclosure Act, credit card issuers are required to post the latest agreements on their websites and to submit them to the CFPB for inclusion in a searchable central database. In this proposed amendment to Regulation Z and the official interpretation, the Bureau said the existing process was too cumbersome for issuers and would thus be suspended while a new system is tested and put in place.
The proposed rule would not suspend the requirement for issuers to post credit card agreements publicly on their own websites.
Comments are due 15 days after publication in the Federal Register.