CBA Submits Comments on Bureau’s Rulemaking Process

June 7, 2018

CBA Submits Comments on Bureau’s Rulemaking Process

WASHINGTON, D.C. – The Consumer Bankers Association today submitted comments on the Bureau of Consumer Financial Protection’s request for information on its rulemaking process.

“CBA recommends the Bureau adopt a standardized rulemaking process that is based on the principles of openness, accessibility and accountability,” CBA Vice President and Senior Counsel Dong Hong wrote.

You may read the full letter here.

The letter includes 12 specific recommendations on ways to promote a standardized and transparent rulemaking process which incorporates public review and input. The letter specifically focused on improvements to the Bureau’s approach to information gathering, cost/benefit analysis, comment process, and final rule implementation and support.

The letter also suggests a model rulemaking framework, below, for consideration by the Bureau.