CFPB Considering Changes to Semi-Annual Credit Card Survey

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

Amendments to the Truth in Lending Act made in 1988 by the Fair Credit and Charge Card Disclosure Act require the CFPB to conduct the TCCP Survey.  The information that the CFPB must collect for the survey is credit card price and availability data from the 25 largest credit card issuers, and no fewer than 125 additional credit card issuers that are distributed equitably and geographically and represent a wide spectrum of institutions.  The TCCP Survey dates are January 31 and July 31.  Data collected since 1990 from the TCCP Survey and other information about the survey is available on the Bureau's website.

The CFPB has published a blog post discussing the updates to the survey that it is considering.  The updates, which are intended to make the survey a more useful resource on credit card price and availability for consumers shopping for credit cards, consist of:

• Collecting median rates by credit score tiers.  Selected issuers would be required to submit data on the median APR offered to consumers in three broad credit score tiers.  According to the CFPB, although issuers frequently disclose the purchase APR as a range based on creditworthiness, consumers do not usually know where they fall within an issuer's APR range until after applying and being approved for a credit card.  In the CFPB's view because an application triggers a hard 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 tiers will better enable consumers to compare realistic APRs across products and estimate the potential cost of borrowing before applying.
• Collecting information on credit cards available to 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 the largest issuers.  However, because these institutions generally do not advertise as widely as the largest issuers, consumers may be unaware of their eligibility for these products.  The CFPB believes that by collecting and disclosing information on requirements for opening these types of accounts, it could "offer a free platform for local organizations focused on relationship banking to find customers."
• Requiring the largest issuers to submit information about more credit cards.  The 25 largest issuers would be required to submit data on each of their general purpose credit cards.  Currently, these issuers only submit information on their product with the largest 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 believes the additional data would help consumers "make choices on which credit cards fits their unique needs, rather than only major issuers' largest cards."  Other institutions selected for the TCCP Survey would continue to be required to report on one product but could voluntarily submit more information.
• Allowing institutions to submit information voluntarily.  A broader range of institutions could volunteer to participate in the TCCP Survey, thereby allowing more issuers to provide information on their credit card offerings and compete with other issuers.  (Concerns about competition, which seem more properly in the FTC's purview than that of the CFPB, have become a recurring CFPB theme.)