3170-0001 Supporting Statement A (2016 Renewal)-1

CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT PART A
REPORT OF TERMS OF CREDIT CARD PLANS (FORM FR 2572)
(OMB CONTROL NUMBER: 3170-0001)

TERMS OF CLEARANCE: None. The Office of Management and Budget (OMB) provided no Terms
of Clearance when it last reviewed this information in July 2013.
ABSTRACT: Form FR 2572 collects data on credit card pricing and availability from a sample of at least
150 financial institutions that offer credit cards. The data enables the Consumer Financial Protection
Bureau (CFPB or the Bureau) to present information to the public on terms of credit card plans.
JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The FR 2572 was implemented in February 1990 as required by Section 5 of the Fair Credit and
Charge Card Disclosure Act (FCCCA) of 1988.1 Each respondent provides information about its credit
card plan with the largest outstanding number of cards. The FCCCA required the Federal Reserve to
collect this information semiannually from the largest 25 issuers of credit cards and at least 125 additional
institutions, in a manner that ensures both an equitable geographic distribution within the sample and
representation of a wide spectrum of institutions. The Federal Reserve was further directed to make the
credit card price information for each institution available to the public upon request and to report the
information semiannually to the Congress
Although the House and Senate Conference Report that accompanied the FCCCA did not explain
specifically why the credit card reports are required, the legislative history suggests that the reports are
intended to facilitate credit card shopping by consumers and thereby enhance competition.2 In this
context, the credit card reports are similar to the Shopper's Guide to Credit that the Federal Reserve
prepared as required by law for the Annual Percentage Rate Demonstration Project in 1984 and 1985.3
Section 1100A of the Dodd-Frank Wall Street Reform and Consumer Protection Act (DoddFrank Act), Public Law 111-203, transferred the authority to conduct the semiannual Report of Terms of
1

The FCCCA was enacted on November 3, 1988, and amends the Truth in Lending Act (TILA) (15 U.S.C. 1601 et
seq). Section 5 of the FCCCA added section 136(b) of TILA (15 U.S.C. § 1646(b). Amendments to Regulation Z
implementing the provisions of the FCCCA were adopted by the Federal Reserve Board on March 30, 1989, with an
effective date of April 3, 1989. Creditors were required to comply with the new disclosure rules by August 31,
1989. See 54 FR 13855 (Apr. 6, 1989).
2

U.S. Congress, Senate, "Report of the Committee on Banking, Housing, and Urban Affairs, to accompany H.R.
515," December 16, 1987. Statements by Edward M. Gramlich, p.12, and Senators Garn, Hecht, Bono, Karnes, and
Shelby, p.14.
3

Board of Governors of the Federal Reserve System, "Annual Percentage Rate Demonstration Project," March
1987.

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Credit Cards, from the Federal Reserve Board to the CFPB on July 21, 2011. CFPB began to collect this
information starting July 31, 2012, and the credit card plan information is now also available at
http://www.consumerfinance.gov/credit-cards/.

2. Use of the Information
Section 136(b) of the Truth in Lending Act (TILA) (15 U.S.C. § 1646(b)) requires the CFPB to
“collect, on a semiannual basis, credit card price and availability information, including the information
required to be disclosed under section 127(c) of TILA (15 U.S.C. § 1637(c)). Section 127(c) requires
issuers disclose, among other things:
 annual percentage rate for purchases (must state if it is a variable rate)
 length of the grace period
 name or description of the balance computation method
 minimum finance charge
 fee for issuance or availability (membership fee)
 fee for late payment
 fee for exceeding credit limit
 transaction fee for purchases
 transaction fee for cash advances.
To report credit card availability information, respondents state whether the credit card plan is
available to consumers nationally (in all 50 states and the District of Columbia) or limited to consumers
within a specific region or state (such as the issuer's home state). Generally, respondents are not required
to fill out each line (corresponding to the states); rather, respondents may fill out one line that describes
the most common terms, and then circle the states in which those terms apply, or fill out the lines for
states in which different terms are offered. In practice, the majority of respondents offer national plans
and fill out only one or two lines on the form. The reporting form also collects information on credit card
plan enhancements, name and address for consumers to obtain a credit card application, and telephone
number for consumer questions.

Reporting Panel
The CFPB follows the selection method the Federal Reserve used to identify the card issuers to
which the FR 2572 is sent, including the 25 largest issuers, by analyzing data on the volume of
outstanding credit card receivables that are reported on the Reports of Condition and Income for
commercial banks (Call Reports) (FFIEC 031 and 041; OMB No. 7100-0036) and for thrift institutions
(OTS Form 1313; OMB No. 1550-023). Like the 25 largest issuers, the other respondents are chosen by
size, but only such that the required diversity of region and type of institution is achieved. The dynamism
of the card industry, with trading of card receivables portfolios and entry into and exit from the industry,
ensures turnover in the panel.
The CFPB distributed the FR 2572 reporting forms to 150 institutions in July 2012 and 160
institutions in January 2013. The number of solicitations extended in January 2013exceeded 150 because
some institutions that do not issue cards were chosen on the basis of holding large portfolios of credit card
receivables. There is a lag of several months between the as-of date of the Call Report data used to
choose the panel and the as-of date of the upcoming FR 2572, and an institution selected for the panel

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may have ceased issuing cards during that period. In addition, the extra solicitations are needed because
the panel may include a number of subsidiaries of the same parent bank, in which case the CFPB will
consolidate the data of these subsidiaries and count them as only one response. Also, on occasion banks
are included if they are offering particularly attractive deals for consumers, regardless of size, as long as
the offer is national. For the preceding reasons, the CFPB plans to increase the number of solicitations to
approximately 200 for each period going forward.
Typically, about 90 percent of the responses come from commercial banks, with the remainder
from savings banks, industrial banks, and savings and loans associations.4 The CFPB added 20 Credit
Unions in January 2013 to increase the representation of such issuers. The panel is consistent with the
criteria of the FCCCA: a reasonable number of creditors of each type, a significant geographic
dispersion, and at least 150 card issuers, including the 25 largest issuers.
Time Schedule for Information Collection and Publication
Twice a year, the CFPB collects credit card price and availability information from a sample of card
issuers on the FR 2572, as of January 31 and July 31. Each respondent must send its data within 10
business days of the as-of date by submitting form FR2572 electronically to a dedicated CFPB email box
([email protected]). Individual respondent data are then published on CFPB’s public website. The reports
are intended to facilitate credit card shopping by consumers and enhance competition.

3. Use of Information Technology
The CFPB changed the submission method from faxing PDF/handwritten forms to emailing
Excel forms electronically in July 2012.
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 the data twice a year and make the
information available to the Congress and the general public. Without this data the public would be
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Retailers are excluded since they are not financial institutions and because their card issuance is limited to storespecific cards. The CFPB may add retailers to the panel at its discretion when it deems it appropriate to do so. The
Report of Credit Card Terms includes credit card banks, such as Discover Bank, which issues the Discover Card,
and American Express Centurion Bank (a subsidiary of the American Express Company), which issues the Optima
Card. It also includes large consumer finance companies that issue credit cards through banks or thrifts.

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hindered in their ability to comparison shop for credit cards and competition would thereby be harmed.

7. Circumstances Requiring Special Information Collection
This collections of information is consistent with the applicable guidelines contained in 5 CFR
1320.5(d) (2). The Bureau notes that we request that entities respond within 10 business days so that we
can provide this information in its entirety to the 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.

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 the proposed renewal of the Form FR 2572. One comment
was received that indicated that the commentor believed that our burden estimate was inaccurate for an
institution like his. However the Bureau believes that aggregated across all respondents our estimates of
the burden of this collection are correct. 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 renewal 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 C.F.R. Part 1070 et seq. There is
no personally identifying information collected by this collection, therefore there is no System of Records
Notice (SORN) or Privacy Impact Assessment (PIA) that is applicable to this collection

11. Justification for Sensitive Questions
This information collection does not include questions of a sensitive nature.
12. Estimated Burden of Information Collection

FR 2572

Number
of
respondents

Estimated
annual
frequency

150

2

Average
time
per response
15 minutes

Estimated
annual
burden
hours
75

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The proposed annual burden for the FR 2572 would be 75 hours. The CFPB is required to collect the
FR 2572 from at least 150 credit card issuers; typically the number of respondents fluctuates right around
150. Since the information collected on the FR 2572 is in nearly all respects identical to information that
card issuers are required to disclose in their credit card solicitations, the FR 2572 imposes little burden.
Associated Labor Costs:
We estimate the labor costs to respond to FR 2572 to be $4,674 based on the following formula:
percentage of staff time, multiplied by annual burden hours, multiplied by hourly rate (30%
Administrative or Junior Analyst @ $25, 45% Managerial or Technical @ $55, 15% Senior Management
@ $100, and 10% Legal Counsel @ $144). Hourly rate estimates for each occupational group are
averages using data from the Bureau of Labor and Statistics (BLS), Occupational Employment and
Wages 2014, http://www.bls.gov/oes/current/oes_nat.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 this form imposes no significant additional material or equipment 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
There are no changes made to agency estimates or adjustments to the reporting population of this
collection that resulted in any change to the burden as previously reported to OMB
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 OMB control number and expiration date for OMB
approval of the information collection on all instruments. The OMB control number and

expiration date associated with this PRA submission will be displayed on the Federal
government’s electronic PRA docket at www.reginfo.gov, as well as in the Federal
Register Notice of the submission.
18. Exceptions to the Certification Requirement

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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.

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