ABA understands that the Bureau is in the process of implementing a step in its rulemaking process that has not previously been a component of consumer financial protection regulation. The implementation of the SBREFA review process is essential to the success of the Bureau’s mission, particularly since the Bureau’s rules will apply to all size institutions, but they only have supervisory experience with the largest providers.Read the statement.
Wednesday, August 1, 2012
SBREFA Process Can Be Improved
ABA submitted a statement for the record for today’s Small Business Committee oversight hearing on the review process for the RESPA-TILA proposal from the Consumer Financial Protection Bureau (CFPB). The comments make it clear that more time is needed for small-entity review, the review panel’s focus should be advocating for small entities, and implementation cost data should be gathered from vendors: