The American Bankers Association and three financial trade associations today urged the White House Office of Management and Budget to publish key information about agencies’ proposed surveys in time for the public to provide fulsome feedback. The request by the associations came in response to the Consumer Financial Protection Bureau’s request for approval, under the Paperwork Reduction Act, of surveys that would help the agency better understand the characteristics of consumers who submit complaints, as compared with consumers who have similar problems but have not submitted a complaint.
Before a federal agency conducts a survey or otherwise collects information from ten or more members of the public, the PRA requires the agency to provide the public with two opportunities to comment and to obtain approval by the Office of Management and Budget. The PRA requires these steps to advance the statute’s purpose to “maximize[s] the utility of information” collected and minimize the burden on survey respondents.
The associations expressed concern that the CFPB had delayed submitting, or OMB had delayed publishing, key information about the CFPB’s proposed Consumer Complaint Survey, including the draft survey instrument, until only 20 days remained in the second of the two public comment periods required by the PRA. The associations urged OMB to require an agency to submit, and OMB to publish, the draft survey instrument, supporting statements and other information at the commencement of the first, 60-day comment period.
