De minimis exception to submitting credit card agreements to the CFPB

Happy Monday! Tomorrow is Halloween and I am looking forward to going trick-or-treating with my niece and nephew. They are both so excited to dress up and get candy (and I may or may not also be excited to snag a piece from them here and there)!

My compliance Halloween treat is a continuation of my last blog, which can be found here. In that blog, I wrote about submitting credit card agreements to the CFPB. At the end of the blog, I mentioned “that there are a few exceptions to the rule which your credit union may want to review. They are located in section 1026.58(c)(5)-(7) and include the de minimis exception, the private label credit card exception, and the product testing exception.”

Now, for this blog, I wanted to provide some more information regarding one of the exceptions in particular. I recently had a question asking whether there was an exemption for small credit unions. While section 1026.58 does not have an exception based solely on asset size, there is a de minimis exception that may be more likely to apply to smaller credit unions. That exception, located in section 1026.58(c)(5), states the following:

 

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