October 1, 2015

Bankers: “We urge the Bureau to re-submit its information collection request with the draft survey instrument.”

Editor’s Note: The following are excerpts from joint PRA comments by major banking and financial services organizations to the Bureau of Consumer Financial Protection. The complete comments are available here.

We, the undersigned trade associations representing the financial services industry, write to express our concern with the Bureau of Consumer Financial Protection’s (Bureau) request for approval under the Paperwork Reduction Act (PRA) to conduct a national web-based survey of 8,000 individuals as part of the Bureau’s study of overdraft protection services. We appreciate the Bureau’s consideration of consumers’ experience with and understanding of overdraft services. However, we are concerned that the Bureau did not include in its submission to the Office of Management and Budget (OMB) a draft survey instrument on which the public could comment, despite OMB guidance requiring publication of the survey simultaneous with the Bureau’s request for comment. We urge the Bureau to re-submit its information collection request with the draft survey instrument.


The data to be collected from the proposed consumer survey will constitute “influential information” subject to these higher standards because the feedback it seeks on consumers’ understanding of overdraft disclosure forms is likely to influence the regulations the Bureau is expected to issue. Therefore, it is critical that the public be given an opportunity to comment on the design as well as the execution of the survey and that OMB be afforded the opportunity to consider those comments as it reviews the PRA request. This can only be accomplished if the draft survey is made available to the public during the first comment period.
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