The Chamber first made suggestions back in July, however many have not been discussed including “those that would significantly eliminate the uncertainty and lack of clarity that continues to cloud the Bureau’s activity and therefore imposes significant costs on the huge number of businesses subject to the Bureau’s jurisdiction.”
In this latest letter, the Chamber suggests several additional steps the CFPB could take to “eliminate inefficiency and unjustified burdens in connection with its supervision and investigatory processes.”
These suggestions include:
- Improving training of supervision staff;
- Applying consistent approaches to examinations;
- Stopping the involvement of enforcement personnel in the examination process;
- Discontinuing the misuse of the supervision process to demand huge amounts of data; and
- Implementing an end point to examinations with a sensible, uniform closing letter process.