Banking and Finance Law Daily Wrap Up, CREDIT, DEBIT AND GIFT CARDS—ICBA urges CFPB to consider portfolio size in credit card plan survey, (Apr 7, 2026)

By Nora Macaluso

The Bureau requested comments on a proposal to revise its Terms of Credit Card Plans survey as part of an effort to reduce regulatory burdens.

The Independent Community Bankers of America (ICBA) urged the Consumer Financial Protection Bureau to use a sampling methodology that takes into account portfolio size as it considers changes to its Terms of Credit Card Plans survey.

The Bureau had requested comments on aspects of a revised renewal of data collection for that survey and its Consumer and College Credit Card agreements. Comments on matters such as the applicability of the survey to purported goals and the accuracy of its estimated annual burden were due by April 7 (see Banking and Finance Law Daily, Feb. 6, 2026).

“The CFPB has an opportunity to reduce an unnecessary regulatory burden on community banks,” IBCA said. Adopting an option that would “restore a sampling methodology that is proportional, statutory, and evidence-based” would help, the association said in their comment letter.

So-called Option B would select respondents based on portfolio size, rather than maintaining the expanded sampling methodology adopted in 2025 (Option A) or resampling every six months for a doubling of annual respondents (Option C), IBCA said.

“Reducing the reporting obligations imposed on small-asset and low-volume issuers will enhance efficiency, align with market structure, and support the Administration’s objective of easing regulatory pressure on community banks,” the association said.

IBCA also recommended that the survey be simplified. “The current expanded data request does collect actual rates offered to consumers,” and “the current TCCP format should be discontinued, as it does not provide for transparency of data,” a key goal of Executive Order 14303, the group said.

Option B would produce a sample reflecting “market realities” more accurately than the other options and would avoid collecting data from “issuers with minimal statistical significance,” ICBA said. It would also reduce unnecessary regulatory burdens on community banks, the comment letter said.

Options A and C, on the other hand, would increase compliance tasks for institutions without large market share, expand reporting obligations without improving utility of the resulting data, and saddle community banks with “disproportionate costs,” ICBA said.

“Both options run counter to the Administration’s stated objective of reducing regulatory burden on community banks, and both rely on unrealistic burden estimates,” the letter said.

Returning to a structure requiring submission from the 25 largest issuers and a sample of 125 additional issuers would be a better solution, according to ICBA.

Companies: Independent Community Bankers of America

RegulatoryActivity: BankingOperations CFPB CommunityDevelopment CreditDebitGiftCards FinancialStability PrudentialRegulation