The American Bankers Association today joined a coalition of financial services trade associations in a follow-up letter to the Consumer Financial Protection Bureau regarding 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 CFPB issued the request in August but 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 trades noted that they “stand ready to provide the CFPB with substantive input from our membership, including on whether the proposed changes will have practical utility; ways to enhance the quality, utility, and clarity of the information to be collected; and ways to minimize the burden of the collection on respondents. Unfortunately, as stated above, the request provides no detail to permit us to provide any such feedback on the CFPB’s proposals.”