Has your credit union met the November 1st deadline to register for Collect?

If your credit union issues credit cards, you may be familiar with Regulation Z, section 1026.57 and section 1026.58. Section 1026.57 requires a credit union that was a party to at least one college credit card agreement, during the calendar year, to submit an annual report to the CFPB. A college credit card agreement is any credit card issued to a college student. Section 1026.58 requires card issuing credit unions, with more than 10,000 open credit card accounts, to submit quarterly reports to the CFPB. An open credit card account is any credit card account where there is a non-charged off outstanding balance or the cardholder can obtain further extensions of credit. Credit unions may want to review the individual sections to determine whether they are required to submit data to the CFPB as other requirements or exceptions may apply.

This brings us to the crux of this blog. On August 23, 2021, the CFPB issued a rule that updated the technical specifications for submitting credit card agreements, data, and information under Regulation Z and the Credit Card Accountability Responsibility and Disclosure Act of 2009. That is, the CFPB has not altered the requirements to submit information, but merely changed how a credit union must submit the required information.

Under the previous submission process, credit unions submitted agreements and agreement information to the CFPB via email. Under the new rule, credit unions will make submissions using the CFPB’s Collect website. To use the Collect website, credit unions must complete the Collect registration form and send it to Collect_Support@cfpb.gov. Here is a letter from NCUA regarding the new rule that may be helpful to credit unions. According to the letter, “credit unions that have registered for Collect in the past do not need to register again.”

 

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