3170-0001 (TCCP) Supporting Statement 30 day FRN OMB

30-day Federal Register version

CONSUMER FINANCIAL PROTECTION BUREAU
SUPPORTING STATEMENT PART A
REPORT OF TERMS OF CREDIT CARD PLANS (FORM FR 2572)
(OMB CONTROL NUMBER: 3170-0001)
TERMS OF CLEARANCE: When the Office of Management and Budget (OMB) last approved this
information collection on May 5, 2016, it instructed the Bureau of Consumer Financial Protection to
display the OMB Control Number and inform respondents of its legal significance in accordance with 5
CFR 1320.5(b). The Bureau has ensured the required PRA statement is on all appropriate instruments.
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 enable the Bureau of Consumer Financial
Protection (Bureau) to present information to the public on terms of credit card plans. The Bureau has
introduced an online channel for submission that has driven down burden costs for participating
institutions.
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 Congress.
FCCCA’s language does not specify why the credit card reports are required. 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
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).

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U.S. Congress, Senate, "Report of the Committee on Banking, Housing, and Urban Affairs, to accompany H.R.

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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 (Dodd-Frank Act),
Public Law 111-203, transferred the authority to conduct the semiannual Report of Terms of Credit Cards
from the Federal Reserve Board to the Bureau on July 21, 2011. The Bureau 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/.
In July 2018, the Bureau began allowing for responses to be submitted through its online channel
“Collect.” About 60 percent of respondents submitted the survey via Collect, and burden to respond
decreased by about one-third.
2. Use of the Information
Section 136(b) of the Truth in Lending Act (TILA) (15 U.S.C. § 1646(b)) requires the Bureau 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). The majority of respondents offer national plans.
Both Collect and the traditional Form 2572 allow respondents to provide information on their most
common terms. The reporting form also collects information on credit card plan enhancements and
telephone number for consumer questions.
Reporting Panel
515," December 16, 1987. Statements by Edward M. Gramlich, p.12, and Senators Garn, Hecht, Bono, Karnes, and
Shelby, p.14.
Board of Governors of the Federal Reserve System, "Annual Percentage Rate Demonstration Project," March
1987.

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The Bureau 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, 051, 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 Bureau distributed the FR 2572 reporting forms to 162 institutions in July 2018 and 168 institutions
in January 2019. The Bureau expects that, for a number of reasons, there will be some level of nonresponse. For example:
1. 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 may
have ceased issuing cards during that period;
2. the panel may include a number of subsidiaries of the same parent bank, in which case the Bureau
will consolidate the data of these subsidiaries and count them as only one response; and,
3. on occasion, banks are included if they are offering particularly attractive deals for consumers,
regardless of size, as long as the offer is national, among other things.
For the preceding reasons, the Bureau plans to increase the number of solicitations to approximately 175
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 In January 2013, the Bureau added
credit unions to its panel in order to ensure 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 Bureau 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 FR 2572 electronically via the Bureau’s online
channel: Collect. Alternatively, respondents able to submit the completed FR 2572 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.
Retailers are excluded since they are not financial institutions and because their card issuance is limited to storespecific cards. The Bureau 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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3. Use of Information Technology
In July 2018, the Bureau began allowing for responses to be submitted through its online channel
“Collect.” About 60 percent of respondents submitted the survey via Collect, and burden to respond
decreased by about one-third.
4. Efforts to Identify Duplication
This data are not otherwise available from any other source.
5. Efforts to Minimize Burdens on Small Entities
The Bureau is required by the FCCCA to populate a sample from both an equitable geographic
distribution and representation of a wide spectrum of institutions. Therefore, some small entities are
included in the panel by necessity. The Bureau has endeavored to make this collection minimally
burdensome to all institutions, and does not expect that small entities experience excess burden compared
to large institutions.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
To meet statutory requirements, the Bureau is required to collect the data twice a year and make the
information available to Congress and the general public. Without this data the public would be hindered
in their ability to comparison shop for credit cards and competition would thereby be harmed.
7. Circumstances Requiring Special Information Collection
This collection of information is consistent with the applicable guidelines contained in 5 CFR
1320.5(d)(2). The Bureau notes that it requests entities to respond within 10 business days in order that it
can provide information in its entirety to the general public in a timely fashion. However, the Bureau
appreciates that this is not always possible for all institutions, and notes 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 published a notice in the Federal Register allowing
the public 60 days to comment on the proposed renewal of the Form FR 2572. The Bureau received only
one comment in response to the renewal of information collection. The commenter stated general support
for the information collection, and did not comment on burden or burden calculation. In accordance with
5 CFR 1320.5(a)(1)(iv), the Bureau published a notice in the Federal Register allowing the public 30
days to comment on the submission of this renewal request to the OMB.
9. Payments or Gifts to Respondents
None.

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10. Assurances of Confidentiality
The information collected will be made publicly available and no assurances of confidentiality are given
to respondents. No personally identifiable information is collected, and the Bureau will treat all
information received consistent with its confidentiality regulations at 12 CFR. Part 1070 et seq. There is
no personally identifiable 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

Collection of
Information
Collection of
Credit Card Plan
Information (via
FR 2572 or
Collect)
Collection of
Credit Card Plan
Information (via
Collect)
One time Collect
registration*

Estimated
Number
of Annual
Respondents

Estimated
Number of
Annual
Responses

Average
Number of
Responses Per
Respondent

Estimated
Average
Response
Time
(hours)

Estimated
Annual
Burden
(hours)

35

2

70

0.18 5

13

140

2

280

.17

48

140 6

1

140

.017

2

175
/////////////
490
////////////////
Totals:
*Respondents who register for the Collect system are a subset of respondents. See note 6.

63

The proposed annual burden for the FR 2572 is 63 hours. The Bureau is required to collect form FR 2572
from at least 150 credit card issuers, but the Bureau expects to expand the total number of surveys sent to
175 in order to receive at least 150 responses as required by the FCCCA. 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 additional burden.

In the January 2019 survey the Bureau received 80% of responses via Collect (10 minutes to respond) and 20% via
[email protected] (15 minutes to respond). The weighted average response time is 11 minutes.
6
There is one time burden associated with registering to use the Collect system. The Bureau estimates that 80% of
respondents will experience burden of 1 minute to complete the registration form. 175 x .8 = 140 respondents
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Associated Labor Costs:
Title (Bureau of
Labor Statistics
Occupation Code)
Market Analyst
(13-1161)
Managerial or technical
(11-2021)
Senior Management
(11-0000)
Legal Counsel
(23-1011)
Total per response

Rate
(USD) 7

Percent
of task

Weighted rate (Rate x
Percent of task, USD)

30.40

30

9.12

Cost per response
(Weighted rate x Average
hours per response, USD)
1.67

63.57

50

31.79

5.83

62.89

15

9.43

1.73

57.33

5

2.87

.53

100

9.75

The Bureau expects that this information collection will cost the average respondent $9.75 in labor costs
to complete and return the FR 2572 form per response. The total average annual labor costs to respond to
FR 2572 to be $3,414. 8 This includes both semi-annual filings.
13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
Since these data are already collected by the respondents 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 Bureau incurs no unique costs as a result of this data collection.
15. Program Changes or Adjustments

Total Annual Burden
Requested
Current OMB
Inventory
Difference (+/-)
Program Change
Discretionary
New Statute
Violation

Total
Respondents

Annual
Responses

Burden Hours

Cost Burden (O &
M)

175

490

63

$0

150

300

75

$0

+25

+190
+140

(12)
-12

7
Hourly median wage found using the Bureau of Labor Statistics May 2017 National Occupational Employment
and Wage Estimates tables available here: https://www.bls.gov/oes/current/oes_nat.htm#23-0000.
8
$9.75 per hour x 175 respondents x 2 per year x 11 minutes per response = $3,413 total average industry cost per
year.

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Adjustment

+25

+50

0

As discussed in section 12 above, in order for the Bureau to obtain the statutorily mandated 150
responses, it sends out at least 175 surveys. Therefore, the Bureau requests enough annual burden to send
the survey to 175 respondents semi-annually. The Bureau estimates that the introduction of Collect will
lower the total industry burden by 11 hours per year. There is a net burden reduction of approximately 12
hours; however, 2 hours are added due to adding a nominal one-time burden for registering for the Collect
system. The Bureau expects that those respondents who use the Collect system will save about 5 minutes
per response (e.g., 15 minutes per response for the paper form verses about 10 minutes per response when
using the Collect system).
16. Plans for Tabulation, Statistical Analysis, and Publication
Individual respondent data are collected and then published on Bureau’s public web site. There are 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, including the Collect registration form. 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

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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