Comment deadline extension needed for CFPB late fee ANPR

June 27, 2022

The Consumer Financial Protection Bureau (CFPB) should extend the comment deadline on its advance notice of proposed rulemaking (ANPR) on credit card late fees and late payments by 60 days, CUNA and other organizations wrote. The CFPB issued the ANPR last week with a 30-day comment deadlines, which CUNA believes is not enough time to collect, analyze, and submit the requested information.

“The information sought in this ANPR is complex and comprehensive, requiring significant analysis and internal coordination to enable firms to provide a meaningful contribution to the public comment record in furtherance of the CFPB’s consideration of credit card late fees and late payments,” the letter reads. “Many of the data points requested have not previously been requested by the CFPB and respondents require more time than has been provided to properly validate their data production methods and to actually produce what is expected to be a large volume of data.”

The letter notes the rule was not included in the Spring Unified Agenda for the CFPB, and the rule had a 60-day comment deadline when originally proposed in 2010 by the Federal Reserve.