Five trade groups, including the American Bankers Association, American Financial Services Association and the Consumer Data Industry Association, recently sent a letter to the Consumer Financial Protection Bureau offering five reasons why the CFPB should solicit public comment on its recently-issued arbitration study before deciding whether to initiate a rulemaking.

Officials insisted through the letter that a formal comment period is essential for five reasons, including:

— Because the study is so long, written comments are the only realistic way for the CFPB to obtain substantive feedback

— There are many business and consumers who will be affected by a rule regulating arbitration whose views have not been solicited

— Soliciting comment now would at least start the process of compensating for the extreme lack of transparency and refusal to solicit public participation that characterized the CFPB’s study process

— Soliciting comment now would allow the CFPB to inform itself of the significant defects in the study’s analysis

— Soliciting public input before embarking on a major rulemaking is consistent with the CFPB’s approach in other contexts.

Joining the ABA, AFSA and CDIA were the Financial Services Roundtable and the U.S. Chamber of Commerce

The organizations wrapped up their letter to CFPB director Richard Cordray saying, “In sum, there are extremely strong reasons why the bureau should provide interested parties with a 60-day period to comment on its study. And it is not clear why the bureau would decline to offer this opportunity.”

The entire letter can be downloaded here.