The Consumer Financial Protection Bureau (CFPB) must release the underlying data on which its credit card late fee proposal is based on, CUNA and other organizations wrote Thursday. The CFPB must also give time for the organizations to analyze the data and form feedback, thus an extension of the comment deadline is also needed.

The proposal would reduce the credit card late fee safe harbor to $8—among other changes—and relies on data from the Federal Reserve Board’s Y-14M data collection.

“We request only that the Bureau release such data in a manner that is anonymized and/or aggregated to the extent necessary to protect confidential bank information. Without this information, it is virtually impossible to understand or replicate the analysis in any meaningful way, significantly hindering the public’s ability to provide thoughtful input,” the letter reads. “The Bureau’s decision to rely on data and analysis that it has not publicly disclosed conflicts with bedrock principles of administrative law.”

The organizations call on the CFPB to publish the data, including methodologies used, immediately, and extend the comment period to “ensure adequate time for the public to review and meaningfully comment on the proposal in light of that information.”

CUNA previously wrote to the CFPB calling for an extension of the comment deadline, noting the bureau did not convene a small business review panel as required by statute.