On January 30, 2012, the American Bankers Association delivered a comment letter  to the CFPB in which it expressed strong disagreement with the CFPB’s proposed policy statement on “Disclosure of Certain Credit Card Complaint Data“. The ABA expressed concern that the complaint data will not help and may actually mislead consumers because it is “incomplete, unrepresentative, and unverified.”… Continue Reading

In an earlier posting, my colleague Mercedes Tunstall reported on the CFPB’s announcement that prior to the designated transfer date (July 21, 2011), it had put in place memoranda of understanding (MOUs) with various other federal agencies. Mercedes also reported that to her dismay, she could not locate copies of those MOUs in any of the usual places such as the Federal Register.… Continue Reading

TransparencyIn Barbara Mishkin’s post on July 25, she questioned why the CFPB’s online questionnaire to be used by cardholders submitting complaints about their card issuers asks the leading question, “Do you believe the issue involved discrimination?”

I have recently learned that, while the CFPB intends to share with card issuers the cardholders’ answers to all other questions contained in the questionnaire, it has refused to let card issuers know the answer to the discrimination question. … Continue Reading