CUNA reiterates call for transparency in CFPB information collection

CUNA joined other organizations in a letter to the Consumer Financial Protection Bureau (CFPB) urging it 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.”

The letter follows a September letter from the same organizations, as the CFPB has not provided specific information on its request for comment regarding reported terms of credit card plans and consumer and college credit card agreements.

“We stand ready to provide the CFPB with substantive input from our membership, including on (1) whether the proposed changes would have practical utility; (2) ways to enhance the quality, utility, and clarity of the information to be collected; and (3) ways to minimize the burden of the collection on respondents,” the letter reads. “Unfortunately, as noted above, the Request provides no detail to permit us to provide any such feedback on the CFPB’s proposals.”

The organizations the CFPB blog post on modernizations the terms of credit card plan survey does not satisfy the CFPB’s obligations under the Paperwork Reduction Act, noting “the public cannot reasonably provide meaningful comments on the value or burden of this vague proposal.”