AFSA Submits Comment on CFPB Debt Collection Quantitative Disclosure Testing

Today, AFSA submitted a comment letter to Mick Mulvaney, the Acting Director of the Consumer Financial Protection Bureau (CFPB) and Director of the Office of Management and Budget (OMB), on its proposed “Debt Collection Quantitative Disclosure Testing.” The bureau is requesting approval from the OMB to conduct a web survey of 8,000 individuals as part of the Bureau’s research on debt collection disclosures. The AFSA letter asks that the OMB deny the CFPB’s request for approval.

The letter noted that, “The CFPB should hold off on conducting the survey until a new CFPB director is confirmed and can evaluate the CFPB’s rulemakings to determine if the survey is necessary. AFSA does not believe that the collection of information is necessary for the proper performance of the functions of the Bureau, nor will it have practical utility.”

The survey would explore consumer comprehension and decision-making in response to debt collection disclosure forms.

Former Federal Reserve economist Tom Durkin wrote regarding the survey that he “…does not expect that this project will prove to be a worthwhile expenditure of the taxpayers’ resources.”