In May, ABA highlighted several methodological and design flaws in the survey — for example, failing to distinguish between experiences with first-party and third-party debt collectors and insufficient management of response bias — but the CFPB responded “only perfunctorily” to feedback from ABA and other groups, the association said. ABA wrote:
The information collection request the bureau has submitted demonstrates a troubling lack of commitment to transparency, public participation, and collaboration. As a consequence, the impact of potential sources of error very likely will be under-disclosed and under-reported.
Read ABA’s letter.