CFPB RFI's

 

In January 2018, the CFPB announced a call for evidence to ensure the Bureau is fulfilling its proper and appropriate functions. The request for information (RFI) process will request public feedback on topics ranging from enforcement, supervisory, rulemaking, market monitoring, and educational activities.  To date, the CFPB has issued RFIs on the following topics:

 

 

Civil Investigative Demands

Comments due April 26, 2018

CBA’s comments will raise various concerns, including, among others, the frequent overbreadth and burdensome nature of the CIDs, the lack of realistic timeframes to respond, and the inadequate Notification of Purpose.

 

Administrative Adjudications

Comments due May 7, 2018

CBA plans to comment, among other things, on the insufficient time allotted to companies to respond to notice of charges, the difficulty of obtaining extensions, and the need for more expansive discovery for respondents.

 

Enforcement Process

Comments due May 21, 2018

CBA’s comments will address a range of concerns, including the lack of coordination of enforcement activity with other agencies, unclear use of responsible conduct, the use of inflammatory press releases, regulation by enforcement, and the length and burden of investigations.

 

Supervision Processes

Comments due May 21, 2018

CBA will be submitting comments.

 

External Engagements

Comments due May 29, 2018

CBA will be submitting comments.

 

Consumer Complaint Reporting

Comments due June 4, 2018

CBA will be submitting comments.

 

Rulemaking Processes

Comments due June 19, 2018

CBA will be submitting comments.

 

Adopted Regulations & New Rulemaking Authorities

Comments due June 19, 2018

CBA will be submitting comments.

 

Inherited Regulations & Inherited Rulemaking Authorities

Comments due June 25, 2018

CBA will be submitting comments.

 

Guidance & Implementation Support

Comments due July 2, 2018

CBA will be submitting comments.

 

Consumer Financial Education

Comments due July 9, 2018

   
Consumer Complaint & Consumer Inquiry Handling Process Comments due 90 days after publication in the Federal Register.