CUNA joined other financial services organizations to request the Consumer Financial Protection Bureau (CFPB) extend the April 20 submission deadline for its revised Terms of Credit Card Plan (TCCP) survey. The organizations request an extension to Sept. 1, the date for the next TCCP survey.

“Because of the lack of a meaningful review period for the updated TCCP survey data, discussed in detail in our earlier comment letters, and because of the complexity and volume of information required by the updated TCCP survey, there is an unreasonably short window for credit card issuers to submit the updated TCCP survey responses,” the letter reads. “Based on the April 20, 2023, deadline, issuers would have only 23 business days to incorporate the additional requirements, organize data necessary to prepare required data points, and prepare the new data for submission.

“With the proposed revised survey schedule, respondents will have three months to organize and report data for all future submissions,” it adds.

The letter also notes:

• The CFPB’s data request is “novel and unclear,” and in a format that requires content not necessarily kept in the normal course of business.
• There are outstanding interpretive questions regarding how issuers should perform calculations and report the data and clarifying FAQs to date have been focused on mechanics instead of substantive interpretations.