Removing Barriers Blog

CUNA Urges CFPB Reissue Notice for Comments on Debt Collection Quantitative Disclosure Testing

Earlier today, CUNA’s Senior Director of Advocacy and Counsel Leah Dempsey, sent a letterto the Consumer Financial Protection Bureau’s Paperwork Reeducation Act Officer in response to the Agency’s request for comment on “Debt Collection Quantitative Disclosure Testing.” 

In the middle of July, CUNA joined with financial trade associations requesting the CFPB to provide additional information for approval under the Paperwork Reduction Act to conduct a national web-based survey of 8,000 individuals as part of the Bureau’s research on debt collection disclosures.  

The Bureau originally provided a draft survey instrument and supporting statements, the materials provided in its submission to the Office of Management and Budget (OMB) are incomplete. The survey instrument asks respondents to answer a series of questions after reading a “financial notice,” but the notice has not been included in the submission to OMB. 

Unfortunately, the additional information has not yet been provided, which makes it impossible to comment on the notice in its current form.  CUNA appreciates the CFPB’s efforts to better understand the debt collection market and believes the survey could be valuable.  As such, CUNA will continue to urge the CFPB to provide the additional information needed to complete such a survey.