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CBA Second 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-2014-0017]
Dear Mr. Vasan:
The Consumer Bankers Association (“CBA”) appreciates the opportunity to respond to the Consumer Financial Protection Bureau’s (“CFPB” or “Bureau”) second request for comments on its proposed “plans to conduct a mail survey of consumers to learn about their experiences interacting with the debt collection industry.”
In our first letter to the CFPB on the initial draft of the survey, CBA made several recommendations to improve the survey in order to gather useful debt collection information, including: clearly distinguishing between creditors and third-party debt collectors; randomizing the consumer survey population, rather than “oversampling” consumers with debt in collections or low credit scores; and verifying the accuracy and validity of responses given by survey respondents.
Based on our review of the revised debt collection survey and its supporting documentation, it appears the Bureau gave some consideration to only one of our recommendations – distinguishing creditors from debt collectors – while leaving unaddressed our other concerns. Unfortunately, the lack of meaningful consideration for these methodological concerns leads us to conclude the survey, as proposed, will not serve as a useful basis for fully understanding consumer experiences with the debt collection system. Therefore, we cannot support the issuance of the survey and would ask the Office of Management and Budget to deny the Bureau’s information collection request (“ICR”).
To read the full Comment Letter, please download the PDF.