In a comment letter on Monday, the American Bankers Association commended the Consumer Financial Protection Bureau for its decision to provide the public with notice and the opportunity to comment each time it conducts testing of consumer financial disclosures. The letter came in response to the bureau’s request to the Office of Management and Budget for re-approval of an existing “generic clearance” to continue testing product disclosures.
Under OMB guidance, the CFPB is not obligated to provide an opportunity for public comment each time it conducts a new round of testing or other information collection under a generic clearance. However, in its request to OMB, the bureau stated it would invite comment each time the bureau tests disclosures.
ABA has previously urged the bureau to provide notice to the public when it seeks to conduct testing on a policy-related topic, such as product disclosures. In its letter, ABA reiterated its call for OMB to require an agency to provide notice whenever the agency seeks to collect information on a rulemaking topic.
