Alert June 10, 2014

CFPB Seeks Public Comment on Information Collection

The CFPB solicited comments on a proposed information collection titled, “Telephone Survey Exploring Consumer Awareness of and Perceptions Regarding Dispute Resolution Provisions in Credit Card Agreements.” The information collection follows a field hearing on arbitration clauses and the release of a study on arbitration clauses (see December 10, 2013 Alert and December 23, 2013 Alert). Section 1028(a) of the Dodd-Frank Act required the CFPB to conduct a study of pre-dispute arbitration agreements and clauses. The CFPB intends to conduct a telephone survey of 1,000 credit card holders to “explore” the role of dispute resolution provisions in consumer card acquisition decisions and consumers’ default assumptions regarding their dispute resolution rights (e.g., consumer awareness without supplementation from external sources) to learn about their experiences interacting with the debt collection industry. The CFPB intends to use the information collected through the survey to inform it in its rulemaking on debt collection. The information collection seeks public input on: (1) whether the collection of information is necessary for the performance of the CFPB’s functions; (2) whether the CFPB’s estimated burden of collecting information is accurate; (3) ways to enhance the information being collected; and (4) ways to minimize the burden on respondents. Comments are due by June 30, 2014.