Comment from Anonymous

This public comment is regarding Docket ID CFPB-2026-0016, SORN, Routine Use 18, at 91 FR 29466. I am a member of the Consumer Financial Protection Bureau (CFPB) Union and am submitting this comment in my personal capacity. I am choosing to submit it anonymously because I fear retaliation from certain CFPB officials for sharing my personal opinion. I am strongly opposed to Routine Use 18, which would allow the CFPB at its own discretion to release current and former employees' personnel records, including information of employees' family members. This unnecessary policy would jeopardize future employment prospects for individual employees, skirt constitutional due process rights by not affording an employee proper notice and opportunity to appeal disclosure or have a hearing on the matter, and would serve no explainable purpose other than to further intimidate CFPB employees into submission -- alumni and current. Because there are no sufficient guardrails in this policy, the CFPB could easily manipulate what constitutes a "legitimate public interest" by being broad and vague in its application and then use disclosure as a looming threat that severely weakens union and whistleblower impact. Employees and alumni -- including me -- would live in fear of personnel files being inaccurate or incomplete but becoming public record and unchallengeable. I worry about the reputational harm that released files will cause because the public's reasonable inference would be "they must have done something wrong for their personnel file to be made public like this." Current federal employees are already well-aware of certain officials' well-quoted goal to have the public "hate" us -- to be vilified for merely doing our jobs. This unprecedented access to yet another part of our lives could only fuel that goal because the public's inference reasonably would be that we "must have done something wrong" if our file was released. And that very well may not be true. I would not feel personally safe for my personnel and personal information to be exposed -- including added risk of identity theft -- and it should go without saying that my family's information bears no relevance to my CFPB career and they should not incur these risks simply because they are related to me. The CFPB has yet to properly and fully explain WHY these personnel records and employees' family information would benefit the public interest or HOW this content amounts to a "legitimate public interest." On the job, I would worry more about my personnel file being wrongly "marred" and released than reporting unlawful, unethical, actions at the CFPB. Our internal checks and transparency in operations would be destroyed. The compound effect of that worry -- across hundreds and hundreds and hundreds of employees and alumni -- would harm everyone. We would be afraid of retaliation so would not do our part to serve the public by calling out waste, fraud, and abuse at the CFPB. That, in turn, would result in an ineffective agency, which would directly lead to consumer protection failures on our watch. To date, the CFPB has offered no compelling reason to allow this violation of citizens' privacy and labor rights. What's the greater and true "legitimate public interest" here: To ensure a fully-functioning CFPB that is not paralyzed by a hostile work environment and can focus on consumer financial protection as Congress intended, or for the government to create yet another unnecessary process that is only intended to threaten and punish past and current CFPB employees?