Comment from Anonymous

I am writing in my personal compacity in strong opposition to the proposed changes to the System of Records Notice (SORN). The proposed change would allow political appointees (or other Bureau employees) to authorize the release of current and former employees’ personal records including sensitive information regarding those employees’ dependents with little to no oversight. The proposed changes appear to be a way for the current Administration or future Administrations to weaponize the potential release of employees’ information. Indeed, Congress has already created a process through FOIA for individuals to request such information, where such requests are vetted by agency attorneys for appropriateness. The idea that a political appointee could order private personal records released for their own partisan “legitimate public interest”, would be a laughable thought if it was not being proposed. Furthermore, the way that “legitimate public interest” is defined is overly broad to the point it could be used to mean anything related to the CFPB. The way it is defined, it is simply the opinion of whoever is ordering the release, which is an absolutely absurd standard. The current proposal could cause significant harm to employees and their families and is a liability to the Federal Government as litigation under the Privacy Act would likely follow if a political appointee ordered such a release. CFPB should scrap this terrible partisan proposal and use the tools that Congress has already given it through FOIA.