In a notice published in today’s Federal Register, the CFPB is seeking public comment on a series of questions about private student loans. According to Rick Hackett, the CFPB’s Assistant Director for Installment Lending Markets, the CFPB wants to hear from “students, families, school counselors, lenders, servicers, and anyone who has anything to do with private student loans” because “hearing [their] stories will help [the CFPB] understand how people make decisions.” The questions are divided into four categories: (1) scope and use of private education loans, (2) information and shopping for private loans, (3) institutional loans, and (4) repayment.
Dodd-Frank requires the CFPB and the Department of Education, in consultation with the Justice Department and the FTC, to submit a report on private education loans and private education lenders to Congress by July 21, 2012. While the CFPB intends to use the input received on its questions in preparing that report, it’s far from clear that the CFPB has the authority to conduct a study of private student loans in the absence of a confirmed Director. The due date for comments is January 17, 2012. Since many of the people from whom the CFPB hopes to hear are unlikely to be regular Federal Register readers, the CFPB’s website also invites comments and includes a link to the notice.