Date: November 4, 2014

Issue: Data Collection


Filing Type: Regulatory

Description: The Office of the Comptroller of the Currency (the “OCC”) has proposed to gather account-level information for what appears to be a substantial majority of the credit cards issued in the United States. That proposal implicates three CCMC priorities: (1) preventing overly broad data collections that impose undue burdens on respondents; (2) preserving customer privacy; and (3) ensuring that regulators use high-quality information in the policymaking process. We accordingly appreciate the opportunity to submit this letter.

Download PDF