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| Calling on CFPB to Improve its Credit Card term Survey Process |
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Credit unions remain committed to offering their members competitive credit card rates and transparent terms. America’s Credit Unions is engaging the CFPB to ensure that the information collection process related to credit card terms is efficient, well-designed, and proportionate to the benefits it delivers.
Responding to the CFPB’s Paperwork Reduction Act request for comment on its survey of credit card terms, Head of Regulatory Affairs James Akin offered changes to reduce burdens and improve the survey process. These suggested changes include:
• Shifting to a change-only reporting model, allowing institutions to submit updated information only for data fields that have changed since their last filing and would provide a signed attestation confirming that all other terms remain the same; and
• Reviewing and refining the criteria that determines which open-end credit card agreements must be submitted, which would improve the overall quality and usefulness of the collected information while reducing unnecessary submissions.
“A more targeted set of submission requirements would help ensure that the CFPB receives the agreements that are most relevant to its supervisory and consumer protection goals, without imposing obligations that capture agreements of limited analytical value,” added Akin.
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