Joint Trades Comment on CFPB Auto Finance Data Project
To whom it may concern:
The American Bankers Association,1 American Financial Services Association,2 America’s Credit Unions,3 Consumer Bankers Association4 , and U.S. Chamber of Commerce5 (the “Associations”) write in regard to the Consumer Financial Protection Bureau’s (CFPB) Paperwork Reduction Act request for comment regarding its proposed new information collection titled “Auto Finance Data Project.” Congress enacted the Paperwork Reduction Act (PRA) to ensure that, when a federal agency collects information from the public, the information collection provides practical benefit to the agency and minimizes the burden on respondents. As such, the Associations urge the CFPB to abandon the new information collection because: (1) the CFPB lacks the legal authority to collect the information; and (2) the CFPB grossly underestimates the burden of the information collection.