CFPB Issues Request for Information on Data Collection

October 2, 2018

The Consumer Financial Protection Bureau (CFPB) seeks comments and information to assist in assessing the overall effectiveness of the bureau’s data governance and collections efforts.

The bureau is considering whether any changes would be appropriate. The comment period ends Dec. 27, 2018. Click here to submit a comment online. Click here for instructions on other ways to submit comments.

The CFPB also issued a report addressing questions concerning the sources of the bureau’s data and its use. It describes what data the bureau collects, where it comes from, and how it is accessed and reused within the agency.

To allow the bureau to evaluate suggestions more effectively, the bureau requests that, where possible, comments include:

  • Specific discussions of any potential changes to its data collection processes, consistent with the laws providing the bureau with data collection authority and the bureau's statutory purposes and objectives, and including, in as much detail as possible, the nature of the requested change, and supporting data or other information on impacts, costs, benefits or information concerning alignment with the processes of other agencies.
  • Specific identification of any aspects of the bureau's approach to its data collections that are working well, and including, in as much detail as possible, supporting data or other information on impacts, costs, benefits or information concerning alignment with the processes of other agencies.

The bureau is seeking feedback on all aspects of its data collections, including the following areas of interest:

  • Best practices for data governance that the bureau should consider adopting; and additional ways that the Bureau can improve its data governance program, including improvements to its processes for collecting data, managing data and releasing data.
  • The bureau's data collection practices related to privacy, including use of aggregated data, use of sampling methodologies, use of de-identified data and de-identification processes, use of direct identifiers, notice to consumers regarding use of data known to be related to them and how the bureau's data collection practices related to privacy compare to other Federal agencies' practices.
  • Changes the bureau should, or should not, make to the sources, uses, and scope of its data collections.
  • How and when data collected primarily for one bureau function should, or should not, be used for other Bureau functions consistent with applicable law. Topics may include:
    • The use of confidential supervisory information or confidential investigation information to inform multiple functions of the Bureau.
    • The use of data obtained for purposes of research, market monitoring, or for assessing the effectiveness of significant rules to inform other functions of the bureau.
    • Reduction of burden on potential furnishers of data by use of the same data by other Bureau functions.
    • Other issues that the bureau should consider when using data collection for a function other than the primary function for which it was collected.
  • Ways to improve data collection processes that reduce reporting burden without hindering the bureau's ability to accomplish statutory objectives. Topics may include:
    • Whether bureau data collections overlap with information maintained by other governmental agencies in a way that makes it difficult or particularly burdensome for institutions to comply.
    • Whether and how the bureau should leverage existing industry data standards for particular markets that the Bureau regulates as part of its data collections.
    • Whether data collection requests are aligned with how institutions maintain information or utilize current technologies.
    • Whether data collections have provided helpful insight into particular markets, and whether there are other collections that would prove more insightful.
    • Ways the bureau may interact with industry or consumer groups to gather suggestions on how to reduce reporting burden and increase the effectiveness of its data collections.
  • Changes the bureau could make to existing data collections, or potential new data collections the bureau could collect, consistent with its statutory authority, to more effectively meet the statutory purposes and objectives as set forth in section 1021 of the Dodd-Frank Act.
  • Other activities that the bureau could engage in to make the data collection requests from financial institutions more effective and efficient.
  • Areas where the bureau has not exercised the full extent of its data collection authority
    • where data collections would be beneficial and align with the purposes and objectives of the applicable federal consumer financial laws.
    • where the bureau can better leverage data as a strategic asset to increase effectiveness.

Contact ALTA at 202-296-3671 or