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NAFCU, along with other trades, wrote to the CFPB Thursday to request the bureau publish the data and analysis it used to justify its credit card late fees proposal. The organizations noted that the bureau relies on data from the Federal Reserve and “refers repeatedly to analyses it conducted using such data.” The groups suggested the inability to view such integral data hinders the public’s ability to give thoughtful comments.

Additionally, the trades pointed out that the Administrative Procedure Act requires the CFPB to release its studies and data when making rules. The groups acknowledged potential concerns with confidentiality but called on the bureau to either release the data in a manner that maintains anonymity or refrain from using the data as justification for the proposal.

NAFCU has consistently engaged the bureau on this proposal. Most recently, the association requested that the CFPB extend the comment period deadline to allow for more time to compile and analyze relevant data.

NAFCU will continue to work the CFPB on this issue and provide updates via NAFCU Today.