Letter to the CFPB on Card Agreement Submission

Dear Mr. May:

The American Bankers Association ("ABA"), representing banks across the regulated financial system, writes in regard to the Consumer Financial Protection Bureau ("CFPB") Paperwork Reduction Act ("PRA") request for comment regarding revisions to the information collection titled "Report of Terms of Credit Card Plans (Form FR 2572) and Consumer and College Credit Card Agreements" ("Request").

Report of Terms of Credit Card Plans

ABA appreciates the CFPB's ongoing engagement on the Terms of Credit Card Plans ("TCCP") Survey. In particular, ABA appreciates the CFPB's recent action to retire its online credit card comparison tool, which the CFPB developed under the prior Administration without express statutory authority and to the detriment of consumers and the broader credit card market. ABA agrees with the CFPB's determination that "[t]he CFPB does not have timely source data to effectively support the purposes for which consumers might want a card comparison tool." As shared with the CFPB in the past, it is ABA's view that the comparison tool created unnecessary reporting burden, risked consumer confusion, and was inferior to private-sector solutions.

ABA also appreciates the CFPB's attention to eliminating data elements in the TCCP Survey that required issuers to provide information beyond the requirement under Section 136(b) of the Truth in Lending Act ("TILA") to collect and disclose "credit card price and availability information."

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