WASHINGTON—CUNA and NAFCU have joined with other financial industry advocacy groups in submitting a letter to the CFPB requesting the agency provide an extension on its comment period regarding its notice of proposed rulemaking (NPRM) on credit card late fees.
“The NPRM proposes significant changes to, and requests wide-ranging comments on, long-standing provisions of Regulation Z,” wrote the groups. “Determining the impact of the proposed amendments to Regulation Z on consumer cardholders using data and models – information lacking from the NPRM – will require considerable time to attempt to gather and analyze relevant information to respond meaningfully to the proposal.”
CFPB Told It Lacks Data
The organizations also argued that failure to provide the industry time to consider the proposed rule would likely result in “an incomplete administrative record and arbitrary agency action, and likely would result in unintended consequences, adverse consumer and small business impact, and ultimately, create flawed public policy.”
Addressing the CFPB’s non-adherence to its obligations under the Small Business Regulatory Enforcement Fairness Act (SBREFA), the groups also said the agency lacks data on the proposal’s impacts.
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