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CBA Comment Letter to CFPB on Debt Collection Survey
RE: Information Collection – Debt Collection Survey from the Consumer Credit Panel, OMB Control Number: 3170-XXXX, [Docket No: CFPB-2014-0005]
Dear Mr. Vasan:
The Consumer Bankers Association (“CBA”) appreciates the opportunity to respond to the Consumer Financial Protection Bureau’s (“CFPB” or “Bureau”) request for comments on its proposed “mail survey of consumers to learn about their experiences interacting with the debt collection industry.”
CBA and its members have been actively engaged with the CFPB as it contemplates writing new rules on debt collection pursuant to its Dodd-Frank authority under section 1089. CBA served as a panelist during the CFPB’s debt collection industry roundtable held jointly with the Federal Trade Commission (“FTC”) last June in Washington, D.C, and we provided comments in response to the Bureau’s Advanced Notice of Proposed Rulemaking on Debt Collections (“ANPR”).
We would like to convey our strong support for surveying consumers in order to advance the CFPB’s “interest in learning about the debt collection system, about consumer experiences with the debt collection system, and about how rules for debt collectors might protect consumers without imposing unnecessary burdens on the industry.”6 As we noted in our ANPR comment letter, we appreciate the measured, deliberative approach the CFPB has taken in the debt collection rulemaking process and the Bureau’s efforts to build on the record developed by the FTC to understand current debt collection practices, and the challenges and opportunities presented by technological and operational advances.
To read the full Comment Letter, download the PDF.