The American Bankers Association and several banking trade groups today called on the CFPB to provide additional information on a recent request for comment on proposed revisions to an existing information collection on credit card terms for consumer and college credit card agreements. The groups noted that the CFPB failed to specify in its initial notice what revisions it is proposing and has not provided appropriate supporting documentation to the public about the request.
While the CFPB published a blog post concurrent with the request that provides several high-level actions it is contemplating—such as requiring selected issuers to submit data on the median APR offered to consumers in three broad credit score tiers—the groups pointed out that this does not fulfill the bureau’s obligations under the Paperwork Reduction Act. “The public cannot reasonably provide meaningful comment on the value or burden of this vague proposal without understanding, for example, who the selected issuers are; how the CFPB intends to calculate the median APR; what value the median APR would have for consumers; what the credit score tiers might be; or how the CFPB plans to account for, and control for, other factors besides credit scores that factor into pricing-related decisions like APRs,” they noted.
The groups requested a supplemental notice offering more clarification on the proposed revisions, and for the bureau to extend the comment deadline by 60 days.