On April 15, the Consumer Financial Protection Bureau issued a final rule suspending for one year the requirement under the Truth in Lending Act and implemented by Regulation Z that credit card issuers submit their card agreements to the CFPB on a quarterly basis.  The CFPB publishes the agreements to a public database on its website.

Other requirements, including card issuers’ obligations to post these agreements on their own websites, will remain unaffected by the rule.  The CFPB says that during the suspension period it intends to manually compile credit card agreements from issuer websites and make them available to consumers on the CFPB’s website.   According to the CFPB, this will help ensure that the database contains agreement terms that are currently offered to consumers by credit card issuers responsible for the substantial majority of existing and new credit cards in the United States.

The final rule adopts the February 2015 proposed rule and took effect immediately upon its April 17, 2015 publication in the Federal Register.

“Today we are finalizing a rule that will help further the Bureau’s work to improve the public credit card agreements database,” said CFPB Director Richard Cordray.  “Updating and streamlining the process for how credit card companies submit their agreements to us can benefit industry and our agency.  Improving this process can also enable consumers and others to access the data faster and in a more useable form.”

Credit card issuers must resume submitting credit card agreements on a quarterly basis starting April 30, 2016.

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Photo of H. Scott Kelly H. Scott Kelly

Scott is a consumer data and privacy specialist. He regularly defends against data breach lawsuits and class action claims asserted under federal and state consumer-protection statutes (FCRA, FDCPA, TCPA, UCC, UDAAP, RICO). Scott represents companies on an array of data privacy issues, including

Scott is a consumer data and privacy specialist. He regularly defends against data breach lawsuits and class action claims asserted under federal and state consumer-protection statutes (FCRA, FDCPA, TCPA, UCC, UDAAP, RICO). Scott represents companies on an array of data privacy issues, including background screening, consumer reporting, data breaches, ransomware attacks, and related regulatory investigations by the Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), and state attorneys general.

Photo of Michael E. Lacy Michael E. Lacy

Michael heads the firm’s Consumer Financial Services practice, and handles class actions and high-stakes consumer litigation on a nationwide basis. He represents banks, mortgage servicers, debt buyers and collectors, and lenders against claims under consumer protection statutes, including the FCRA, TCPA, RESPA, RICO,

Michael heads the firm’s Consumer Financial Services practice, and handles class actions and high-stakes consumer litigation on a nationwide basis. He represents banks, mortgage servicers, debt buyers and collectors, and lenders against claims under consumer protection statutes, including the FCRA, TCPA, RESPA, RICO, and state UDAP laws. He has significant experience litigating and trying corporate governance disputes, including shareholder derivative claims, corporate dissolution cases, and corporate divorce matters. Michael also represents public utility companies in litigation and regulatory matters, including condemnation and land use cases.