“ABA believes that establishing comparable accountability across all providers of comparable financial products and services is a fundamental mission” of the Consumer Financial Protection Bureau (CFPB).
The CFPB has explained that the larger-participant rule will not impose substantive consumer protection requirements. Instead, the rule will enable CFPB to begin a supervision program for larger participants in certain market.
ABA wrote that the process of identifying larger participants should begin by delineating the individual markets in which participants’ activity levels will be compared.
We believe that this analysis involves two components: the definition of broad product markets followed by the consideration of the appropriate geographic scope of each product market.
Once relevant markets have been delineated, then the non-depositories who serve those markets can be identified as ‘larger’ by measuring their share of those markets among like entities.ABA emphasized that establishing comparable accountability across all providers of comparable financial products and services is a fundamental CFPB mission.
See the letter.
See the CFPB’s request for comment.