«Via Federal Express July13, 2015 The Honorable Richard Cordray Bureau of Consumer Financial Protection 1275 First Street, NE Washington, DC 20002 Re: Comments on the Bureau’s Consumer Arbitration ...»
The Associations believe that the Bureau’s Study, inadequate as it is in many respects, nevertheless clearly supports a conclusion favoring pre-dispute arbitration agreements. We urge the Bureau to recognize and give full credit to the many pro-arbitration findings in the Study and to the other issues raised in this letter when it begins its policy deliberations. Moreover, we urge the Bureau to solicit public comment on the Study so that all interested stakeholders will have an opportunity to express their views on the important issues presented and amplify the record of information available before the Bureau decides whether to initiate a rulemaking. Without doing so, we do not believe that the Bureau, based upon the evidence presented to the public, can meet the test established by Congress for imposing new rules to limit, restrict, or otherwise prohibit consumer arbitration, an effective avenue for redress relied upon each year by many consumers.
M. Delikat and M. Kleiner, “An Empirical Study of Dispute Resolution Mechanisms:
Where Do Plaintiffs Better Vindicate Their Rights?,” Disp. Resol. J. Nov. 2003 – Jan.
2004, at 56.
L. Bingham, “Is there a Bias in Arbitration of Nonunion Employment Disputes? An Analysis of Actual Cases and Outcomes,” 6 Int’l J. of Conflict Mgmt. 369 (1995).
DMEAST #22199841 v1 Respectfully submitted,
K. Richard Foster Senior Vice President & Senior Counsel for Regulatory and Legal Affairs Financial Services Roundtable 600 13th Street, NW Suite 400 Washington, D.C. 20005 Tel: 202 589-2424 E-mail: firstname.lastname@example.org cc: Dan Smith Will Wade-Gery (via email) DMEAST #22199841 v1