WASHINGTON—The CFPB is being reminded of its obligations under the Paperwork Reduction Act in a joint letter from five financial institution trade groups that includes NAFCU and CUNA.
The letter was sent in response to the Bureau’s notice and request for comment regarding the Report of Terms of Credit Card Plans and Consumer and College Credit Card Agreements.
The letter requests response from the CFPB to a prior letter sent in September that recommended the Bureau issue a supplemental notice clarifying the proposed revisions to the existing information collection and extend the comment deadline to 60 days from the date of issuance of such a supplemental notice.
Reminding the Bureau of obligations under the Paperwork Reduction Act (PRA), the groups stated that Congress enacted the PRA to ensure that “when a federal agency conducts a survey or otherwise collects information from the public, the survey or information collection provides practical benefit to the agency and minimizes the burden on survey respondents.”
The letter reiterated the groups’ interest in responding to a fulsome request from the CFPB, noting that the previously requested information has not yet been provided by the Bureau.
The trades also urged the CFPB to publish a notice and request for comment that would permit meaningful public comment on any proposal amending credit card issuers’ obligations to report on credit card terms and to submit credit card agreements.
Additional Information Sought
Additionally, the letter seeks additional information on whether a CFPB-run card comparison site would offer justifiable benefits above those from existing private sector sites. The trades told the Bureau that a blog post on its Terms of Credit Card Plans Survey does not meet the obligations of the Bureau under the PRA as it relates to the collection of information.
“Given the proliferation of free, commercially available platforms that enable consumers to compare credit card products and assess eligibility, we strongly urge the CFPB to comply with the PRA requirement to solicit comment on whether such a requirement would be ‘necessary for the proper performance of the functions’ of the CFPB, and whether ‘the information will have practical utility,’” stated the groups.
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