Comment on CFPB-2013-0016

Arbitration vs Litigation, is it the most pressing issue the CFPB should be considering right now regarding credit cards? I encourage the CFPB to immediately research pre-credit card default issues that are causing poor consumer treatment once a default occurs. Pre-Credit Card Default issues include... 1. Why is unsecured debt so easily converted to secured debt by the courts? If the debtor has already agreed there is a debt and simply needs the debt suspended for a period of time or the monthly payment amount reduced, why are courts eagerly converting unsecured credit card debts to secured debt? 2. Why are credit card companies allowed to advertise "Pro-Family" commercials on television (The Capital One Jimmy Fallon advertisements are perfect examples) when they sue debtors who had to stop working to provide caregiving services for elderly parents (writer raises hand). 2A. Why are there no credit card television commercial warning labels that state the truth, "Warning, we consider your credit card debt to be more important than any life changing event that may occur in your life, please never miss a payment or face litigation". 3. The Consumer Federation of America (CFA) and the Center for Economic Justice (CEJ) claimed "more than 2.5 billion of the almost 6 billion paid by consumers for credit insurance in 2000 came as overcharges that could have been avoided if state regulators had followed their own rules" (end quote). We might find that less than 10 percent of that 6 billion dollars actually was returned to the consumer in the form of claims. This amounts to debt suspension insurance price fixing that STOLE the most logical way for a credit card debtor to protect themselves in times of legitimate crisis. 4. In 2002 the Comptroller of the Currency held Debt Suspension hearings and proclaimed credit card companies could retain a Debt Suspension Insurance price fixing monopoly, a very strange reaction to point number 3, no? I have solutions.