CFPB considering changes to semi-annual credit card survey | Ballard Spahr LLP

The CFPB invites comments on changes to its semi-annual Survey of Credit Card Plan Terms (TCCP). Comments must be submitted by October 17, 2022.

Amendments to the Truth in Lending Act in 1988 by the Fair Credit and Charge Card Disclosure Act require the CFPB to conduct the TCCP investigation. The information that the CFPB needs to collect for the survey is credit card prices and availability data from the top 25 credit card issuers, and no less than 125 additional credit card issuers that are evenly and geographically distributed and represent a wide range of institutions. The dates for the TCCP survey are January 31 and July 31. Data collected since 1990 from the TCCP survey and other survey information is available on the Bureau’s website.

The CFPB published a blog post discuss updates to the investigation he is considering. The updates, which aim to make the survey a more useful resource on credit card price and availability for consumers purchasing credit cards, consist of:

  • Collection of median rates by credit score levels. Selected issuers would be required to submit data on the median APR offered to consumers in three major credit rating tiers. According to the CFPB, although issuers frequently disclose purchase APR as a range based on creditworthiness, consumers generally do not know where they fall within an issuer’s APR range until they have requested and approved a purchase. credit card. In CFPB’s view, because one application triggers a credit inquiry that can negatively impact a consumer’s credit score, some people may be hesitant to apply for multiple credit cards. As a result, some consumers may be discouraged from searching widely for the best rate. The CFPB believes that allowing consumers to see the median APR for their credit score levels will allow them to better compare realistic APRs between products and estimate the potential cost of borrowing before applying.
  • Collection of information on available credit cards for specific communities or groups. According to the CFPB, many smaller institutions such as regional banks and credit unions offer credit cards to people in particular communities or with specific affiliations at better rates than larger issuers. However, since these institutions generally do not advertise as widely as larger issuers, consumers may not be aware of their eligibility for these products. The CFPB believes that by collecting and disclosing information on the conditions for opening these types of accounts, it could “provide a free platform for local organizations focused on relationship banking to find customers”.
  • Require larger issuers to submit more credit card information. The 25 largest issuers would be required to submit data on each of their general purpose credit cards. Currently, these issuers only submit information about their product with the highest number of accounts. According to the CFPB, the largest issuers represent the vast majority of the credit card market, and many of them offer dozens of products with different combinations of rates, fees and rewards. The CFPB says the additional data would help consumers “make choices about credit cards that fit their unique needs, rather than larger cards from major issuers.” Other institutions selected for the TCCP survey would continue to be required to report a product, but could voluntarily submit more information.
  • Allow institutions to voluntarily submit information. A wider range of institutions could volunteer to participate in the TCCP survey, allowing more issuers to provide information about their credit card offerings and compete with other issuers.

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