The American Bankers Association, Consumer Bankers Association, Credit Union National Association, National Association of Federally-Insured Credit Unions, and U.S. Chamber of Commerce (the Associations) appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s (Bureau) request for approval under the Paperwork Reduction Act (PRA) of an information collection titled “Junk Fees Timing Study” (Timing Study).The Bureau seeks approval of the Timing Study under the Generic Information Collection titled “Generic Information Collection Plan for Studies of Consumers Using Controlled Trials in Field and Economic Laboratory Settings.”4 As discussed in greater detail below, the Timing Study does not fall under the limited uses that the White House’s Office of Information and Regulatory Affairs (OIRA) permits for a generic clearance.
