Joint Trade Letter on Arbitration Survey

Ladies and Gentlemen:
The Financial Services Roundtable,  the Consumer Bankers Association,  and the American Bankers Association appreciate the opportunity to comment on the request by the Consumer Financial Protection Bureau (the “Bureau”) for information concerning a proposed survey of “consumer awareness of dispute resolution provisions in their agreements with credit card providers,” and “[w]ays to enhance the quality, utility, and clarity of the information to be collected” in the course of the survey.

We urge the Bureau not to proceed with the proposed survey. As designed, the survey is inconsistent with the Consumer Financial Protection Act (“CFPA”) mandate and is flawed in concept and execution. Instead, we urge the Bureau to conduct rigorous and sound peer-reviewed research comparing the various methods of consumer dispute resolution, notably, litigation and arbitration, and thus satisfy the Congressional mandate articulated in Section 1028 of the CFPA.

To read the full Comment Letter, download the PDF.