MCUA Comments on CFPB Telephone Survey Regarding Dispute Resolution Provisions
On August 6, 2013, the Missouri Credit Union Association (MCUA) filed a comment letter on the Consumer Financial Protection Bureau's (CFPB) request for approval by the Office of Management and Budget (OMB) for the CFPB to conduct a telephone survey. Specifically, the CFPB intends to survey 1,000 consumers regarding their awareness and perceptions of dispute resolution provisions in credit card agreements. The survey is in conjunction with the CFPB’s study of pre-dispute arbitration agreements, as required by the Dodd-Frank Act.
It is MCUA's understanding that, while most credit unions do not utilize pre-dispute arbitration agreements, a small number of credit unions may incorporate similar provisions into their consumer contracts. As noted in the August 6 letter, while, at this time, MCUA does not have any formal objections to a survey by the CFPB, they urge the agency to ensure it utilizes a sample size that is adequate to yield a sufficient number of informed respondents. Once proposed, MCUA will review and comment on the CFPB’s draft survey.