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CONSUMER FINANCIAL PROTECTION BUREAU

PAPERWORK REDUCTION ACT SUBMISSION

INFORMATION COLLECTIONS REQUEST

SUPPORTING STATEMENT PART A

CONSUMER AND COLLEGE CREDIT CARD AGREEMENT 

(OMB CONTROL NUMBER: 3170-XXXX)

OMB TERMS OF CLEARANCE: Not applicable. This is a request for a new OMB control 

number.

ABSTRACT: 

Sections 204 and 305 of the Credit Card Accountability Responsibility and Disclosure Act of 2009 

(CARD Act) and 12 C.F.R. §§ 226.57(d) and 226.58 require card issuers to submit to the Consumer 

Financial Protection Bureau (CFPB):

 agreements between the issuer and a consumer under a credit card account for an open-end 

consumer credit plan; and

 any college credit card agreements to which the issuer is a party and certain additional 

information regarding those agreements.

The data collections enable the CFPB to provide consumers with a centralized depository for consumer 

and college credit card agreements. It also presents information to the public regarding the arrangements 

between financial institutions and institutions of higher education. 

PART A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

Pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), 

Section 502(a) of the CARD Act requires periodic reviews of the consumer credit card market, within the 

limits of the Bureau’s existing resources available for reporting purposes. As enacted in 2009, the CARD 

Act directed that the Federal Reserve Board (FRB) conduct this review. The CFPB and the FRB

concluded in May 2012 that responsibility for this review will be transferred to the CFPB, along with the 

general transfer of rulemaking authority for the Truth in Lending Act.

As set forth in the statute, these collections seek to examine developments in the consumer credit card 

marketplace, including: 

 effectiveness of disclosure of terms, fees, and other expenses of credit card plans; 

 adequacy of protections against unfair or deceptive acts or practices relating to credit card plans.

Consumer Credit Card Agreement Quarterly Submission
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On July 21, 2011, the CFPB assumed responsibility under the CARD Act for quarterly collecting credit 

card agreements in a publicly available database. Pursuant to 12 CFR 1026.58; 15 USC 1632(d)(2)-(3); 

collection is mandated for all issuers (subject to de minimus exceptions), and scope of mandate may 

require submission of multiple different agreements for each issuer.

College Credit Card Agreement Annual Submission

This collection is made pursuant to the CARD Act requirement: 12 C.F.R. § 1026.57(d); 15 U.S.C. § 

1637(r); 76 FR 79768 (Dec. 22, 2011). 

Every year, the CARD Act requires the CFPB to collect the agreements in place between credit card 

issuers and institutions of higher education, as well as summary data about the credit cards offered 

pursuant to these agreements. 

The CARD Act requires the CFPB to submit to Congress, and to make available to the public, an annual 

report that lists information submitted to the Bureau concerning agreements between credit card issuers 

and institutions of higher education or certain affiliated organizations.1 Affiliated organizations include 

fraternities, sororities, alumni associations, or foundations affiliated with or related to an institution of 

higher education. CFPB provides this centralized depository on its website and also publishes an annual 

report each year based upon the submitted data. 

Similarly to the quarterly credit card agreement submission, this role was also inherited from the Federal 

Reserve Board. 

The annual submission of college credit card agreements has previously approved by the Office of 

Management and Budget, and bears OMB approval number 7100-0199. 

2. Use of the Information

Consumer Credit Card Agreement Quarterly Submission

Every quarter, the CARD Act requires the CFPB to collect and post to CFPB’s website credit card 

agreements from issuers with over 10,000 accounts. Financial institutions must submit consumer credit 

card agreements quarterly by the first business day on or after January 31, April 30, July 31, and October 

31 of each year, as described in 12 C.F.R. § 226.58.

Consumer agreement submissions generally must reflect the consumer agreements an issuer offered to the 

public as of the last business day of the preceding calendar quarter. For example, the submission due on 

January 31, 2014 (the first business day on or after January 31, 2014) must reflect the consumer 

agreements your institution offered to the public as of December 31, 2013 (the last business day of the 

fourth calendar quarter).

The CFPB is required by law to make all such agreements “easily accessible and retrievable.” They are 

posted on CFPB’s site: http://www.consumerfinance.gov/credit-cards/agreements/. The agreements can 

 

1 The Consumer Financial Protection Bureau (the “CFPB”) submits this report in accordance with Section 305 of the 

Credit Card Accountability Responsibility and Disclosure Act of 2009 (the “ CARD Act”), Pub. L. No. 111–24, § 

305(a), 123 Stat. 1734, 1749-50 (2009). 
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be filtered by issuer and the text is fully searchable. This facilitates consumers’ ability to find their credit 

card agreement and compare it to others.

College Credit Card Agreement Annual Submission

Every year, the CARD Act requires the CFPB to collect the agreements in place between credit card 

issuers and institutions of higher education, as well as summary data about the credit cards offered 

pursuant to these agreements. 

College agreements must be submitted annually by the first business day on or after March 31 of each 

year, as described in 12 C.F.R. § 226.57(d). For example, if an institution was a party to a college credit 

card agreement in effect at any time during calendar year 2013, the agreement and information about that 

agreement must be sent to the CFPB after December 31, 2013, and no later than March 31, 2014.

The agreements between the financial institution and the institution of higher education and information

about those agreements are considered nonconfidential. The CFPB will make these agreements and the 

related information available to the public as part of an annual report.

Agreements between a financial institution and an institution of higher education and information

about those agreements are considered nonconfidential because:

 Section 304 of the Credit CARD Act and 12 C.F.R. § 226.57(b) require institutions of higher 

education to disclose these agreements publicly; and

 Section 305 of the Credit CARD Act requires the Board to submit to Congress and make

available to the public an annual report that lists certain information about each agreement

submitted.

This information includes:

 the total amount of payments by your institution during the year;

 the specific terms of the agreement under which payments are calculated;

 the number of accounts opened during the year; 

 the total number of accounts that were open at the end of the year; and

 a list of agreements terminated during the calendar year including the name, type, and location of 

the institution of higher education.

This data collection is intended to bring greater transparency to the college and university credit 

card market. The CARD Act prohibits credit card issuers from extending credit without 

assessing the consumers’ ability to pay, specifically persons under the age of 21. This collection 

is vital to the ongoing regulatory surveillance of this potentially risky market segment. The 

collection also provides consumers, including college students, clear and comparable information 

regarding their credit cards. 

The college credit card data is posted at https://data.consumerfinance.gov/Government/College-CreditCard-Agreements/r963-hvsf. 

3. Use of Information Technology

The CFPB changed the submission method from faxing PDF/handwritten forms to emailing Excel forms 

electronically in July 2012. This change was non-materialand has made the form submission efficient and 

timely and reduced logistical burden.
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4. Efforts to Identify Duplication

This data is not otherwise available from any other source.

5. Efforts to Minimize Burdens on Small Entities

None of the entities affected by this data collection can be classified as small entities.

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction

To meet statutory requirements, the CFPB is required to collect these data quarterly and annually and

make the information available to the Congress and the general public. Without CFPB’s quarterly 

collection of agreements, consumers may not have access to the latest and up-to-date agreement 

disclosure. Also, without this data the public would be hindered in their ability to comparison shop for 

credit cards and competition would thereby be harmed. Further, the Card Act requires CFPB to submit 

to Congress and make available to the public an annual report that lists certain information 

regarding the arrangements between credit card issuers and institutions of higher education. 

7. Circumstances Requiring Special Information Collection

The Bureau notes that we request that entities respond within 10 business days so that we can provide this 

information in its entirety to general public in a timely fashion. However we appreciate that this is not 

always possible for all institutions, and note that, comporting with OMB rules regarding information 

collections, an entity has up to 30 days to make the required response.There are no special circumstances 

requiring special information collections. These collections of information is otherwise consistent with 

the applicable guidelines contained in 5 CFR 1320.5(d) (2). 

8. Consultation Outside the Agency

In accordance with 5 CFR 1320.8(d)(1), the Bureau has published a notice Federal Register allowing the 

public 60 days to comment on this collection of information. Further and in accordance with 5 CFR 

1320.5(a)(1)(iv), the Bureau will publish a notice in the Federal Register allowing the public 30 days to 

comment on the submission of this information collection request to the Office of Management and 

Budget. 

9. Payments or Gifts to Respondents

None.

10. Assurances of Confidentiality

The information collected will be made publicly available and no assurances of confidentiality are given 

to respondents. No personally identifying information is collected, and the Bureau will treat all 

information received consistent with its confidentiality regulations at 12 CFR Part 1070.20 et seq.

11. Justification for Sensitive Questions
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This information collection does not include questions of a sensitive nature. 

12. Estimated Burden of Information Collection

Information Collection 

Requirement

No. of 

Respondents

Frequency Number of 

Annual 

Respones

Average 

Response Time

(hours)

Annual Burden 

Hours

Quarterly Credit Card 

Agreement Submission

400 4 1,600 .25 400

Annual College Credit 

Card Agreement 

Submission

30 1 30 1 30

Totals: 430 ////////////// 1,630 //////////////////// 430

The proposed annual burden for the quarterly credit card agreement submission would be 400 hours. The 

CFPB is required to collect the agreements from at least 350 credit card issuers; typically the number of 

respondents fluctuates around 400. Since these agreements collected are readily available by the card 

issuers (and usually already publicly disclosed), this requirement imposes little burden.

Associated Labor Costs:

Quarterly agreement credit card agreement submission

We estimate the labor costs to submit the credit card agreements quarterly to be $20,840 based on the 

following formula: percentage of staff time, multiplied by annual burden hours, multiplied by hourly rate 

(30% Administrative Services Manager @ $43, 70% Operations Manager @ $56,). Hourly rate estimates 

for each occupational group are averages using data from the Bureau of Labor and Statistics (BLS), 

Occupational Employment and Wages, May 2013, http://www.bls.gov/bls/blswage.htm. Occupations are 

defined using the BLS Occupational Classification System, http://www.bls.gov/soc/. 

The proposed annual burden for the annual college credit card agreement submission would be 

30 hours. Typically the number of respondents fluctuates around 30. Since these agreements collected 

are readily available by the card issuers (and usually already publicly disclosed), this requirement imposes 

little burden.

Annual Credit Card Agreement submission 

We estimate the labor costs to submit the annual college credit card agreement to be $1,605 based on the 

following formula: percentage of staff time, multiplied by annual burden hours, multiplied by hourly rate 

(30% Administrative Services Manager @ $43, 50% Operations Manager @ $56, and 20% Legal 

Counsel @ $63). Hourly rate estimates for each occupational group are averages using data from the 

Bureau of Labor and Statistics (BLS), Occupational Employment and Wages, May 2013, 

http://www.bls.gov/bls/blswage.htm. Occupations are defined using the BLS Occupational Classification 

System, http://www.bls.gov/soc/. 

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers 

Since this data is already collected by the respondent in their ordinary course of business, reporting it on 
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this form imposes no significant additional costs on them.

14. Estimated Cost to the Federal Government

None. The CFPB incurs no unique costs as a result of this data collection.

15. Program Changes or Adjustments

Since this is a request for a new OMB control number, all the burden associated with this collection of 

information is considered to be a program change. Further, theses statutorily required collections have 

been conducted by the Bureau without a currently valid OMB control number. Therefore, the program 

change will be classified as “Change due to PRA Violation.”

16. Plans for Tabulation, Statistical Analysis, and Publication

Individual respondent data are collected and then published on CFPB’s public web site. There is no 

complex analytical techniques being used. The final presentation of the information does include basic 

search, filter and sort functionalities.

17. Display of Expiration Date

The Bureau plans to display the expiration date for OMB approval of the information collection on all 

instruments.

18. Exceptions to the Certification Requirement

The Bureau certifies that this collection of information is consistent with the requirements of 5 

CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3) and is not seeking an exemption 

to these certification requirements.