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Wednesday, April 25, 2012

ABA Suggests Improvements to the SBREFA Review Process

ABA wrote a letter to Richard Cordray, Director of the CFPB, Cass Sunstein, OIRA administrator, and Winslow Sargeant, Chief Counsel for SBA’s Office of Advocacy to suggest improvements to the Small Business Regulatory Enforcement Fairness Act (SBREFA) review process to ensure the small business review Congress chose to add to Bureau rule making is meaningful and results in consumer protection rules that work for both consumers and small entities.

The letter noted concern with the short period of time for Small Entity Representatives (SER) selection, preparation and participation.
The aspirations of the SBREFA process – information gathering, collaboration, and consensus-building around less burdensome alternatives to achieve a regulatory goal – take time, and ABA is concerned that the process and timetable established by the Bureau for SBREFA review is inadequate.
In addition, ABA encouraged CFPB to gather and make available to SERs information third-party service providers about potential implementation costs and to ensure that there is ample opportunity for discussion of less burdensome alternatives to the regulatory proposals being considered.

Read the full ABA letter.

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