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February 01, 2013

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Michael Holmes

Steve,

Did I miss something here? The respondent panel is the 25 largest issuers plus 125 additional. That's 150. So why did they send the survey to 160 institutions? Is that in case some do not reply? But if the response is mandatory, they should not need replacements. The CFPB is giving me a headache, I can't imagine what they are doing to you.

Steve Van Beek

Michael - good points. Section 136 of TILA indicates the survey should be "at least 125" additional financial institutions. It looks like in their survey sample they went above and beyond. Unfortunately, they didn't consider the amount of notice and time credit unions would need. On that issue, they did the absolute bare minimum and that is very frustrating for an agency that sold itself on being a "21st Century Regulator" and committed to transparency.

Brian Witt

The Survey form is posted on the CFPB website and is actually quite benign. The credit card terms requested in the Survey form are just the basic card terms that could be readily pulled from any card issuer's credit card agreement, which are posted on the CFPB site anyway. CFPB's survey seems to be a quicker way for CFPB to assemble the data from a very small subset of card issuers, than actually assembling the data itself.

Steve Van Beek

Brian - those points bring up a natural question: Why is Section 136 of TILA still in place after the Credit CARD Act? A good question for lawmakers to consider. If the information is already being provided to the CFPB in the quarterly submissions, why require these 160 institutions to do additional legwork?

The more disconcerting part is the CFPB's continued failures when it comes to communicating issues to regulated entities (and those who try to help them comply).

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