CBA Letter to OMB re Student Loan Data Collection

October 6, 2017


Office of Management and Budget

New Executive Office Building

Room 10235

Washington, DC 20503


RE: Docket No. CFPB-2017-0023; OMB Control Number: 3170-0064; Student Loan Servicing Market Monitoring


Dear Sir or Madam,


The Consumer Bankers Association (“CBA”)[1]  appreciates the opportunity to comment on the proposed “Student Loan Servicing Market Monitoring” information collection.  As the voice of the retail banking industry, CBA membership includes private sector lenders who make the majority of private student loans to help families finance a college education.  In addition, our members include organizations that are generally experienced in working with federal student loans, having participated in the Federal Family Education Loan Program (FFELP) and, in some cases, currently holding FFELP loans.    


CBA appreciates and shares the interest of the Consumer Financial Protection Bureau in the private student loan marketplace being transparent and fair, providing consumers – our members’ customers – with loans that help them meet their goals of attaining a quality college education.  CBA members make the majority of private student loans today, playing an important role in making the American dream of a college education possible. 


CBA also believes that part of attaining that dream is doing so at a cost that is appropriate for the result achieved – a degree that leads to a good-paying job.  Our members are finding that their student and parent customers are succeeding both in educational attainment and in successfully repaying their private student loans.  Our members spend tremendous resources in designing loan products tailored to meet their customers’ needs, and they are careful to make loans to customers who are judged highly likely to repay them.  The result has been excellent performance across the marketplace.  This performance is documented by comprehensive, voluntary data reporting regularly available to the public and policy-makers through the organization MeasureOne, reporting that is currently serving the market well. 


In light of the current MeasureOne reporting, CBA believes that the proposed new information collection would be duplicative and would offer few benefits while creating major unnecessary costs for our members. Further, CBA rejects the notion that collection of this data is warranted by the “at-risk” populations our members serve. CBA members have demonstrated great performance in the private student loan marketplace, and the collection of new data will only disrupt our members who have seen continuing improvements in their loan portfolios, even as volume has increased.  Finally, CBA argues that the CFPB can collect the data requested just as efficiently, and with less risk to the confidentiality of the data provided by our members, through the supervisory process.  As such, CBA respectfully asks that OMB reject this data collection proposal and advise the Bureau to either (1) obtain the desired student loan data from the Department of Education and from the MeasureOne report, or (2) to use the supervisory process to gather the desired data from private student loan lenders.


[1] The Consumer Bankers Association is the only national financial trade group focused exclusively on retail banking and personal financial services – banking services geared towards consumers and small businesses.  As the recognized voice on retail banking issues, CBA provides leadership, education, research, and federal representation for its members.  CBA members include the nation’s largest bank holding companies as well as regional and super-community banks that collectively hold two-thirds of the total assets of depository institutions. Our members operate in all 50 states, serve more than 150 million Americans and collectively hold two-thirds of the country’s total depository assets. A list of our corporate membership can be found at

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