The Credit Union National Association (CUNA) recently joined a group of organizations asking the Consumer Financial Protection Bureau (CFPB) to extend the deadline to comment on the bureau’s proposal on credit card late fees.
The CFPB proposed the rule last month with a 60-day comment period. CUNA would like the comment period extended by at least another 60 days.
The CFPB’s proposal includes “novel and unanticipated” amendments to Regulation Z, including a late payment fee cap of 25 percent of the minimum periodic payment. CUNA officials would like more time to process the proposal.
“Determining the impact of the proposed amendments to Regulation Z on consumer cardholders using data and models – information lacking from the [proposal] – will require considerable time to attempt to gather and analyze relevant information to respond meaningfully to the proposal. Failure to provide sufficient time for industry to consider the proposed rule’s impact on consumers would result in an incomplete administrative record and arbitrary agency action and likely would result in unintended consequences, adverse consumer and small business impact, and ultimately create flawed public policy,” CUNA’s letter to the CFPB states.
CUNA also pointed out that the CFPB did not convene a small business review panel for the proposal, as required by statute.
“A rush to finalize significant changes to a long-standing rule that has endured through CFPB leadership appointed by both political parties, without providing sufficient time for commenters to provide data and other information on consumer and market impacts, would invite scrutiny and the likelihood of future revision, which would not benefit anyone,” the letter states. “We respectfully request that the CFPB give industry and the public sufficient time to provide data-driven comments that will promote sound and durable policy decisions.”