CBA Reiterates Concerns about Bureau’s Proposed Complaint Rating System

December 28, 2016

On December 28, 2016, CBA submitted a joint comment with the American Bankers Association responding to the CFPB’s proposed “Consumer Response Customer Response Survey.”  In the letter, the trades asked the CFPB to refrain from finalizing the proposal because, under the Paper Reduction Act (PRA), the Office of Management and Budget (OMB) should only approve a data collection if the information collection is “necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility.” 

CBA asserted the collection would not have practical utility and, therefore, should be denied because the subjective rating system will only compound the Database’s existing problems of disseminating unverified information.  Further, concerns remain about the privacy issues raised by the expanded data collection in the event of a data breach and reidentification of the sensitive information published.

As background, there are two comment periods required under the PRA before the OMB considers a new regulatory collection.  On September 30, 2016, the trades responded to the first comment request, which voiced similar concerns.