Joint Trades Request re: Extension to Comment Period on CFPB Complaint Narratives Proposal

Ladies and Gentlemen:

On July 16, Director Cordray announced that the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) was considering adopting a policy to expand the manner in which it discloses certain complaint data it receives regarding consumer financial products and services via its web-based, public-facing database (the “Consumer Complaint Database”). Specifically, the proposed policy would permit individuals to authorize the Bureau to post a narrative description of their complaint on the Consumer Complaint Database.

The Financial Services Roundtable, American Bankers Association, the Consumer Bankers Association, The Clearing House and the U. S. Chamber of Commerce (the “Associations) will be working with their respective members to comment on the CFPB’s proposal.

The proposal raises many serious legal and practical issues and thirty days is simply not enough time for us and our members to analyze and respond to the proposal. The Associations request that the Bureau extend the comment period to not less than 90 days following publication in the Federal Register.

Our request for an extension of time is based on two considerations. First, a longer comment period is consistent with the standards that other federal agencies must follow. Executive Order 13563, dated January 18, 2011, states that agencies are expected to promote public participation by affording “at least 60 days” for public comment. Although the Bureau is not legally bound by this Executive Order, we encourage the Bureau to follow the good government standards that other agencies follow, especially since there is no statutory deadline or other reason to apply a different standard. In addition, we note that affording at least 60 days would align the Bureau with the Consumer Product Safety Commission when it considered implementing its public database. 75 FR 29156 (May 24, 2010).

To read the full Comment Letter, please download the PDF.