Credit Union National Association sent this letter to the Bureau of Consumer Financial Protection (BCFP) regarding its request to the Office of Management and Budget to allow the bureau to continue collecting certain documents from credit card issuers for public disclosure on their website. Specifically, card issuers must submit to the bureau: (1) agreements between the issuer and consumer for a consumer credit card account; and (2) any college credit card agreements to which the issuer is a party and certain additional information regarding those agreements.

“While at first very onerous, since credit unions have been complying with these requirements for the better part of the past decade, the compliance burden has declined,” the letter reads. “We acknowledge the benefit to consumers of being able to easily access the bureau’s website to review and compare credit card agreements across all issuers. To ensure agreements are submitted on a timely basis, we ask the CFPB to send quarterly reminders to card issuers.”

While the bureau’s request for comment focuses on the collection of credit card agreements, CUNA used the letter as an opportunity to reiterate concerns regarding credit card disclosures. CUNA encourages the bureau to explore the overall effectiveness of credit card disclosures, as well as ways in which disclosures, including those mandated by the CARD Act, that can be simplified. The CFPB has acknowledged, and the association agrees, that overly complex disclosures are less effective in informing consumers about the terms of a financial product.

The letter further requests that the CFPB continue to look for ways to improve disclosures as they relate not only to the consumer but also to affected financial institutions.