Source: Shutterstock.
NAFCU, CUNA and four other groups filed a letter with the CFPB on Wednesday to ask the agency for clarification surrounding its proposal to changes to current language inside credit card agreements as it relates to collections.
The problem is, according to the group's letter, the CFPB did not specify what the proposed revisions are.
The letter, filed by the American Bankers Association, Bank Policy Institute, Consumer Bankers Association, CUNA, NAFCU and United States Chamber of Commerce, stated the only information they've seen from the CFPB came from a blog post on the agency's website. The letter stated, "the Blog Post proposes a series of high-level considerations that do not satisfy or substitute for the information required to be provided to the public by the Paperwork Reduction Act that the public can evaluate and comment on."
Therefore, the six groups asked the CFPB for two things:
- Issue a supplemental notice clarifying the specific proposed revisions to the existing information collection.
- Extend the comment deadline to 60 days from the date of such a supplemental notice.
"The public cannot reasonably provide meaningful comment on the value or burden of this vague proposal without understanding, for example, (i) who the selected issuers are; (ii) how the CFPB intends to calculate the median APR; (iii) what value the median APR would have for consumers; (iv) what the credit score tiers might be; or (v) how the CFPB plans to account for, and control for, other factors besides credit scores that factor into pricing-related decisions like APRs," the letter stated.
It continued, "If the series of vague considerations cited by CFPB staff in the Blog Post are, in fact, the revisions that the CFPB is proposing and seeking comment on, we respectfully request that the CFPB issue a supplemental notice clarifying its specific proposed revisions to the existing information collection in detail sufficient to enable stakeholders to evaluate the utility of the proposed changes and balance the utility against any burden imposed."
As of now, comments on the proposed changes are due to the CFPB by Oct. 17.
© 2025 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
Michael Ogden
Editor-in-Chief at CU Times. To connect, email at [email protected]. As Editor-in-Chief of CU Times since 2016, Michael Ogden has led the editorial team in all aspects of content strategy and execution, including the creation of the publication’s exclusive and proprietary research database of the credit union industry’s economic landscape. Under Michael’s leadership, CU Times has successfully shifted to an all-digital editorial product with new focuses on the payments, fraud, lending and regulatory beats. Most recently, he introduced a data-focused editorial product for subscribers that breaks down credit union issues into hard data, allowing for a deeper and more factual narrative for readers. In 2024, he launched the "Shared Accounts With CU Times" podcast, which offers a fresh, inside-the-newsroom perspective through interviews with leaders from the credit union industry and the regulatory world. He dives into pressing credit union issues, while revealing the personalities working behind-the-scenes to push the credit union world forward. His background includes years as a radio and TV anchor/reporter and a public relations and digital/social media manager, where he covered the food and music industries, as well as cooperatives and credit unions. Over the years, he has launched numerous exclusive video and podcast series, including a successful series of interactive backstage interviews with musicians at music festivals, showcasing his social media and live streaming production skills.
