ABA: CFPB’s Debt Collection Study Proposal Subverts PRA Process

ABA today commented on the Consumer Financial Protection Bureau’s request for approval under the Paperwork Reduction Act to conduct a survey as part of its study of debt collection disclosures.

While ABA supports the CFPB’s overall goal of gaining a better understanding of how consumers comprehend and respond to debt collection notices, the association opposed the bureau’s request because it declined to provide the materials necessary for meaningful comment. Specifically, ABA noted that the CFPB failed to provide for comment a copy of the financial notice that participants in the study would be asked to read and respond to, as required by the PRA process.