Summary: Notice of Expiration of Suspension

Submission of Credit Card Agreements Under the Truth in Lending Act (Regulation Z)/Consumer Financial Protection Bureau

Prepared by the NASCUS Legislative and Regulatory Affairs Department
April 2016

The Consumer Financial Protection Bureau (CFPB) issued a notice reminding credit card issuers that they are required by the Truth in Lending Act (TILA) and Regulation Z to submit their currently offered credit card agreements to the CFPB to be posted on the Bureau’s website.  The notice can be found here.

  • In April 2015, the Bureau amended Regulation Z (which implements TILA and the official interpretation of that regulation) to temporarily suspend the submission obligation for a one year period.  That suspension period has expired and the next submission is due on May 2, 2016 (the first business day on or after April 30, 2016).  The submission must include credit card agreements that were offered to the public as of March 31, 2016.
  • Section 1026.58(g) of Regulation Z and comment 58(g)-2 detail which agreements must be submitted to the Bureau and notes that credit card issuers are to submit the agreement “in the form and manner specified by the Bureau.” The CFPB issued an email containing submission instructions to credit card issuers on March 30th.  The instructions can be accessed here.
  • Note, the submission requirement does not impact card issuers’ obligations to post currently offered credit card agreements on their publicly available websites and to make agreements for open accounts available to cardholders.