WASHINGTON—The CFPB does not understand the scope of what it is asking regarding a proposed new information collection related to auto lending, according to a number of groups that includes credit unions.
As a result, the groups say, the CFPB should abandon its request for comment under the Paperwork Reduction Act (PRA).
America’s Credit Unions joined with other organizations in making the request in a letter to the agency that argues the Bureau lacks legal authority to collect the information outlined in the proposal and “grossly underestimates the burden of the information collection.”
The proposed new information collection – the “auto finance data project” – would annually require lenders that originate greater than 20,000 auto loans in the previous calendar year to furnish the Bureau with an expansive data set including, but not limited to, at least 16 distinct data points.
Misunderstood ‘Magnitude’
The organizations said the proposed collection includes a burden estimate that is “so low that it suggests the CFPB does not understand the magnitude of the data request,” wrote the groups.
In the proposal, the Bureau estimates that the data request will impact 4,000 respondents for an estimated total annual burden of 1,375 hours – which breaks down to 20 minutes per respondent. But America’s Credit Unions and the other organization say that estimate is off “by a magnitude of 3,000.”
Lack of Authority Alleged
In support of their position the CFPB lacks legal authority to collect the information outlined in the auto finance data project, the groups stated the Bureau does not have the authority to conduct this data collection and, if approved, the collection would result in the unlawful gathering and analysis of personally identifiable financial information.
The organizations also suggested the proposed collection is unnecessarily duplicative of information otherwise reasonably accessible to the bureau and the collection request is excessively burdensome.
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