NAFCU’s Letter To CFPB Regarding Credit Card Agreements

January 28, 2013

The Honorable Richard Cordray
Consumer Financial Protection Bureau
1700 G Street, NW
Washington, DC 20552

RE: Quarterly Submission of Credit Card Agreements

Dear Director Cordray:

On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents federal credit unions, I am writing to you regarding the Consumer Financial Protection Bureau’s (CFPB) practices related to quarterly collection of credit card agreements.

The CFPB, pursuant to its regulations, collects credit card agreements in a publicly available database.  Issuers, including credit unions, must complete a worksheet on a quarterly basis.  NAFCU has heard from a number of members that the process should be improved.  Based on our members’ observations, we request that you take the following actions to facilitate compliance.

First, credit unions have simply not been provided adequate time to comply with submission requests.  NAFCU believes the CFPB should provide credit unions at least 30 business days from the time the agency’s request for submission is sent to the issuer.   Next, the CFPB should allow each credit union to have multiple “contact persons” to whom the request for submission is transmitted.  Currently, the CFPB only contacts a “point person.”  While NAFCU has learned that a credit union can request that additional persons are “copied” on the electronic transmission that the CFPB sends, the agency can and should take additional steps and provide flexibility in regards to the number and identity of persons at credit unions to whom the request is sent.  This can be done, for example, by allowing a credit union to indicate on a form whether it would like to update contact information, adding, or removing one of more points of contacts.

NAFCU appreciates your attention to this matter.  If you have any questions or concerns, please feel free to contact me at (703) 842-2215 or Tessema Tefferi at (703) 842-2268.


B. Dan Berger
Executive Vice President, Government Affairs

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