On May 5, 2014, ACA International submitted comments in opposition to the Consumer Financial Protection Bureau’s Debt Collection Survey from the Consumer Credit Panel.
While ACA appreciates the CFPB’s desire to understand the complexities of the debt collection market prior to exercising its rulemaking function, ACA strongly encourages the CFPB not to proceed with the proposed survey. The CFPB’s justification of the need for the information request is lacking, and the proposed survey is conceptually deficient.
In its comments, ACA stresses that the proposed survey would not yield statistically sound data and therefore will not enable the CFPB to improve its understanding of the debt collection market in support of potential rule writing.
The survey is flawed in design and the content suffers from substantial negative bias. As such, it is highly unlikely that the CFPB will be able to draw credible conclusions from the proposed survey, as the data obtained will be highly unreliable and misleading.