The CFPB’s proposal to issue “no-action letters” in response to requests for feedback on product innovation does too little to reduce regulatory uncertainty, according to a comment letter yesterday from ABA, its American Bankers Insurance Association subsidiary and the Consumer Bankers Association.
“By its terms the Bureau’s proposed approach is limited in its applicability and yet fraught with perils for the requester,” the groups explained. “It is hard to imagine how it would serve as a viable approach to alleviating regulatory uncertainty, either for the requester or anyone else.”
The associations added that the limited scope, likelihood of failure, lack of confidentiality and lack of usefulness for compliance would provide “virtually no incentive for innovators to undertake the request process.”
Read the letter.