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Thursday, October 18, 2012

ABA Recommends the CFPB Focus on Qualitative Research for Credit Card Consumers

ABA submitted a comment letter to the CFPB yesterday regarding its request for comment on an institution's new short-form credit card agreement and its existing long-form agreement. ABA commented that the proposed survey would yield little useful information and that the CFPB should focus its resources elsewhere:
While we appreciate the Bureau’s intent to obtain data and conduct consumer testing, we believe that the proposed survey will yield little if any useful information in determining the best way to ensure that consumers notice and understand the credit card terms that are important to them... We recommend that the Bureau instead focus its resources on qualitative research that examines what information related to their credit card consumers believe they need and find useful and the best means of delivering that information so that consumers notice and understand that information.
ABA also requested that the OMB reject the CFPB's request for emergency clearance to conduct the research:
Furthermore, we believe that the Bureau’s hyperbole that this particular survey should receive “emergency” clearance because it is “essential” to its mission should be rejected and that the standard information collection process should apply, including requiring the public provision of all relevant components of the information collection--such as the agreements to be tested--before submission to OMB.
Read ABA's comment letter.

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