Limited, targeted questions, as well as efficient informationcollection methods, should be used to minimize burdens and costs oncredit unions when the Consumer Financial Protection Bureau collects information aboutcompliance costs, CUNA has written to the agency.

In a comment letter to the CFPB released Wednesday, CUNARegulatory Counsel Dennis Tsang said CFPB should fully understand and minimize thepotential implementation and ongoing compliance costs andunintended consequences on credit unions from its potential newregulations.

However, he pointed out that the process the agency hasdelineated for collecting the information may be more burdensome oncredit unions, particularly smaller ones.

“While the CFPB estimates that responding to the proposedinformation collection requests may take up to 90 minutes perresponse, we believe respondents will have to spend much more timeto understand and research the potential regulatory changes and thenumerous areas that may be affected at their institution and atthird parties they may use, as well as coordinating a response toagency,” he wrote.

“To minimize costs for respondents, the CFPB should developlimited, targeted questions, and provide additional resources toassist respondents with this information collection,” the lettersaid.

Tsang also suggested that sampling institutions that arerepresentative of the markets affected by the CFPB rulemakings canbe more efficient than broader inquiries.

“The agency should utilize proper statistical and researchmethods to ensure a representative sample for each affected marketto properly measure compliance costs,” Tsang wrote. “Otherinstitutions that are not part of the sample should have an optionto submit their information after reviewing the informationcollection materials.”

The CUNA attorney also urged the CFPB to consider the highpotential compliance costs and other effects on credit unions,especially smaller credit unions, with regard to the agency'sproposed mortgage, remittance transfer and other regulations.