WASHINGTON—NAFCU and CUNA have joined with other financial services trades in a letter to the White House over the CFPB’s plans to collect information on junk fees without going through the proper processes.
More specifically, the letter was sent to the White House Office of Information and Regulatory Affairs (OIRA) in response to the Bureau’s request for approval under the Paperwork Reduction Act (PRA) of a proposed information collection, “Junk Fees Timing Study.
In the letter, the groups have urged OIRA to disapprove the Bureau’s request for approval of the timing study, noting that it clearly “concerns a substantive and policy issue.”
In addition, the groups argued the title of the request strongly suggests that the Bureau intends to use the data collected in connection with its on-going policy work to restrict so-called “junk” fees, which includes overdraft fees and credit card fees.
The trades asked ORIA, should it approve the Bureau’s request, to impose an explicit term on its approval that prohibits the Bureau from using the survey results to inform any Bureau rulemaking or other policy action.
Information Lacking
In addition, the groups criticized the Bureau for seeking comment on the proposed study without providing any other information related to it, aside from a one-sentence abstract outlining the study. Any additional information will not be published until after the May 18 comment period closing, which prohibits the public’s ability to comment on the survey instrument, methodology used to find respondents, and any other aspect of the study, they wrote.
The trades said OIRA should require the Bureau to resubmit the request through the full PRA process.
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