WASHINGTON — America’s Credit Unions is urging the Consumer Financial Protection Bureau to scale back and modernize its credit card data collection requirements, arguing the current process imposes significant burdens on credit unions without delivering corresponding consumer benefits.
In a comment letter submitted to the CFPB, which is signed by James Akin, head of regulatory advocacy, the trade group said the agency’s “Report of Terms of Credit Card Plans” survey has long required substantial staff time, coordination and manual data entry, costs that fall most heavily on smaller institutions.
America’s Credit Unions acknowledged that the CFPB’s now-discontinued credit card comparison tool had previously highlighted the competitive advantages of credit unions. Citing CFPB analysis from 2024, the group said small banks and credit unions offered lower interest rates than the 25 largest credit card issuers across all credit tiers, with APR differences of 8 to 10 percentage points, translating to roughly $400 to $500 in annual savings for a consumer carrying a $5,000 balance.
However, with the comparison tool no longer available, the organization said the cost-benefit balance has shifted.
“The CFPB is asking institutions to continue bearing the full cost of an expanded data collection without a corresponding public-facing use for that data,” America’s Credit Unions wrote.
Recommendations Offered
The trade group outlined several recommendations for revising the survey process, including:
- Improve clarity: Provide more detailed, field-level instructions to reduce inconsistent reporting caused by ambiguous questions.
- Modernize the submission system: Address limitations in the CFPB’s data portal, including the inability to save partial entries or share drafts internally for review.
- Expand technical support: Offer more timely assistance for institutions encountering portal or access issues during reporting periods.
- Adopt “change-only” reporting: Allow institutions to report only updated data fields rather than re-entering unchanged information each cycle, while using simplified reporting for APR updates.
- Refine submission criteria: Narrow which credit card agreements must be reported to focus on those most relevant to supervisory and consumer protection goals.
‘Raises Risks of Errors’
The organization said requiring full re-entry of unchanged data not only increases costs but also raises the risk of errors, while a more targeted approach would improve both efficiency and data quality.
America’s Credit Unions said it remains committed to working with the CFPB to ensure the reporting framework is “efficient, well-designed, and proportionate to the benefits it delivers.”
