news.cuna.org/articles/114111-cuna-card-agreement-submissions-easier-reminders-helpful

CUNA: Card agreement submissions easier, reminders helpful

April 30, 2018

The Bureau of Consumer Financial Protection should send quarterly reminders about submitting credit card agreements, CUNA wrote to the bureau Monday. CUNA’s letter was sent in response to a bureau request to the Office of Management and Budget to continue collecting certain documents from credit card issuers.

Card issuers are required under the CARD Act to submit to the bureau agreements between issuers and consumers, as well as any college credit card agreements to which the issuer is a party.

“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,” the letter reads. “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.”

“We ask the CFPB to continue to look for ways to improve disclosures as they relate not only to the consumer but also to affected financial institutions,” the letter reads. “However, we urge the bureau to be mindful of the financial resources credit card issuers incur with each change to a required disclosure—even if that change is minor. In addition, any changes contemplated by the bureau should retain the responsibility of consumers to review their billing statements.”

In its letter, CUNA also reiterated more general concerns about credit card disclosures. In particular, CUNA encouraged the bureau to explore the overall effectiveness of credit card disclosures, as well as ways in which those disclosure can be simplified.

CUNA further requested that the bureau continue to look for ways to improve disclosures as they relate not only to the consumer but also to affected financial institutions.