The Center for Capital Markets Competitiveness (“CCMC”) appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau (“CFPB”) regarding its notice and request for comments regarding the information collection titled “Report of Terms of Credit Card Plans (Form FR 2572) and Consumer and College Credit Card Agreements” (the “RFI”).
The RFI states that the CFPB “is requesting to revise an existing information collection, titled ‘Report of Terms of Credit Card Plans (Form FR 2572) and Consumer and College Credit Card Agreements.’” The CFPB does not explain, however, how the CFPB intends to revise this information collection. It summarizes the credit card data the Bureau collects (specifically, the Terms of Credit Card Plans Survey and data collected from issuers pursuant to Sections 204 and 205 of the Credit Card Accountability Responsibility and Discharge Act of 2009 and 12 C.F.R. §§ 1026.57(d) and 1026.58)., the RFI does not provide any details on the changes the CFPB has in mind. Further, although the RFI states that documents prepared in support of the revisions can be accessed at www.regulations.gov, no such supporting documentation is available there. As a result, it is impossible for stakeholders to provide informed comments on the changes the CFPB may be contemplating.