The Chamber is concerned with the CFPB’s lack of transparency surrounding the collection of this data which have made it “difficult to evaluate the prudence and the legality of the collection process.”
The Chamber notes the CFPB may be in violation of the Dodd-Frank Act.
From the letter:
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- The statute requires that the Bureau issue an order or regulation in order to collect this information, but the Bureau has done neither.
- The statute restricts the Bureau’s ability to collect consumers’ personally-identifiable information, but it is not clear that the Bureau has in place appropriate safeguards to ensure compliance with that limitation.