ABA offered several suggestions to improve the CFPB’s proposed consumer survey on debt collection experiences. Although ABA supported the survey, it cautioned that the survey “will likely fall short” of producing data that can be relied on for policymaking.
Specifically, the proposed survey fails to distinguish between experiences with first-party and third-party debt collectors, ABA said. The bureau should also pre-test survey questions, design the survey to manage response bias and conduct the survey exclusively online, the association added.
Read the comment letter.