In a comment letter yesterday, ABA challenged the Consumer Financial Protection Bureau’s improper use of a streamlined review process to conduct research related to overdraft services without providing the public with notice and an opportunity to comment on its research approach. The association pointed out that the bureau has used the “generic clearance process” to conduct surveys and other information collections on substantive and policy-related issues, such as overdraft, even though guidance published by the Office of Management and Budget prohibits using the generic clearance process for this purpose.
ABA urged the bureau to seek approval for a standard clearance if it desires to collect information on a substantive or policy issue. This would provide the public with an opportunity to comment on the collection request and make suggestions for improving the methodology of the research.
