The new generic information collection clearance, for which the CFPB intends to seek OMB approval, is titled “Generic Clearance for Consumer Complaint and Information Collection System (Testing and Feedback).” According to the CFPB, the clearance “will allow the Bureau to test and pilot new and improved questions and requests for information. Stakeholder feedback will be used by Consumer Response to inform program improvements and enhancements as well as establishing their priority.” To justify its request, the CFPB states that the development of new questions and improvement of existing complaint questions “would benefit from the streamlined flexibility of the generic clearance process.” Comments on the proposal are due by August 26, 2013.
The latest clearance proposal appears to be an add-on to a generic information collection clearance proposed by the CFPB in October 2011. That proposal sought generic clearance for intake forms, response forms and feedback collection used in the CFPB’s complaint system. In the notice of its new proposal, the CFPB indicates that it continues to invite comments on the 2011 proposal.
The American Bankers Association and the American Financial Services Association both submitted comment letters opposing the 2011 proposal. The ABA viewed the proposal as
“[s]hort circuiting the Bureau’s obligations to continue to obtain public and industry comment on a process that presents issues at each implementation phase.” AFSA argued that a generic clearance was inappropriate because it was necessary for the CFPB’s complaint system to reflect the differences between financial products. AFSA also discussed deficiencies in the CFPB’s existing complaint forms that needed to be addressed before using the forms for other financial products. The CFPB’s new proposal is also likely to meet with the objection that a generic clearance will deny the public and industry an opportunity to comment on the appropriateness and utility of new questions used in the complaint system.
The CFPB’s other (and likely noncontroversial) proposed information collection is titled “Evaluations of Financial Capability Programs for Economically-Vulnerable Consumers: Two Randomized Evaluations.” According to the CFPB, this collection is aimed at understanding “whether bundled products and services that are designed to build savings and credit for economically-vulnerable consumers have an impact on assets building and financial capability.” (In its first Financial Literacy Annual Report, the CFPB used a prepaid card with a savings function as an example of a bundled financial product.) The collection will be targeted at low-income consumers who are considered “unbanked, underbanked, or have thin or no credit files.” The CFPB intends to collect information about the financial health of these consumers (such as the amount of savings, credit score, debt to income ratio) and their financial capability. Comments on the proposal are due by September 30, 2013.