The CFPB published a notice in the Federal Register today announcing that it will continue to take comments until August 22, 2014 on its plans to seek approval from the Office of Management and Budget “to conduct a mail survey of consumers to learn about their experiences interacting with the debt collection industry.”
The Federal Register notice published by the CFPB on March 7, 2014 announcing the CFPB’s plans to conduct the survey required comments to be filed on or before May 6, 2014. We previously questioned the CFPB’s ability to draw valid conclusions from many of the responses it receives and observed that because contact with a debt collector is not an event that a consumer can be expected to welcome, there appeared to be a substantial risk that consumer bias will produce responses that do not accurately reflect consumers’ actual experiences.
Our concerns about the survey’s ability to produce reliable and representative data that can be used to inform any related rulemakings or other agency actions were shared by the American Bankers Association and Consumer Bankers Association who submitted comments to the CFPB. Other than the ABA, AFSA and CBA, only ACA International has submitted comments so far on behalf of industry. Given the survey’s shortcomings and the CFPB’s plans to use the survey results to inform its debt collection rulemaking, we hope more industry members will weigh in.