With comments closed on 12 RFIs, three topics dominate public response to consumer agency

One week after the “comments due” date had passed on the final of 12 requests for information (RFIs) from the federal consumer financial protection agency, the total of 88,564 letters received overwhelmingly focuses on three topics, with more than 97% of all comments received.

According to tallies of comments posted by Regulations.gov (a federal government web-based portal supporting the federal rulemaking process), the three topics are RFIs focusing on the agency’s: supervision programs (55,049, or 62.2% of all comments); public reporting practices of consumer complaint information (23,262, or 26.3%); and use of civil investigative demands (CIDs) (8,023, or 9.1%).

The topics were among three of a dozen RFIs that the Bureau of Consumer Financial Protection (BCFP, formerly known as the CFPB) began issuing in January to fulfill Acting Director John “Mick” Mulvaney’s “call for evidence” to determine if the agency is fulfilling its job.

Of the 12 RFIs issued, only four generated 1,000 or more comments; the remaining eight were far behind, with the highest at 437 comments, the lowest at 33 (the comments averaged 147 per topic). Those remaining eight accounted for 1.3% of all comments received.

When Mulvaney announced the series of RFIs Jan. 17, he said his call for evidence of the agency’s functions in performing its role through the RFIs was being conducted to provide the public an opportunity to provide feedback and suggest ways to “improve outcomes for both consumers and covered entities.”

“In this New Year, and under new leadership, it is natural for the Bureau to critically examine its policies and practices to ensure they align with the Bureau’s statutory mandate,” Mulvaney said. “Moving forward, the Bureau will consistently seek out constructive feedback and welcome ideas for improvement.”

Since then, the agency has given little insight into how the comments would be used. However, BCFP has employed the comments from one RFI to shore up its changes to the make up and memberships of its advisory committees.

On June 6, the agency stated (in a blog post) that it was “reconstituting” its consumer, bank and credit union advisory panels advisory panels to “new, smaller memberships. The panels provide industry input and advice to the BCFP. “By both right-sizing its advisory councils and ramping up outreach to external groups, the Bureau will enhance its ability to hear from consumer, civil rights, and industry groups on a more regular basis,” the bureau stated.

The changes, the bureau said, were partly in response to comments received on its RFI on bureau external engagements (which closed for comments May 29).

Reguations.gov has counted 67 total comments received for that RFI. Those comments account for less than 1% (0.08%) of all the comments the agency has received in the series of RFIs.

To date, the agency has indicated no action related to the top three topics for which it has received comments.