CBA Comment Letter re RFI on Adopted Regulations and New Rulemaking Authorities

The Honorable Mick Mulvaney

Acting Director

Bureau of Consumer Financial Protection

1700 G Street NW

Washington, DC 20552


RE: Request for Information Regarding the Bureau’s Adopted Regulations and New Rulemaking Authorities, Docket No. CFPB-2018-0011


Dear Acting Director Mulvaney:


The Consumer Bankers Association (“CBA") appreciates the opportunity to provide the Bureau of Consumer Financial Protection (“BCFP” or “Bureau”) with our comments in response to the notice and request for information (“RFI”) on Adopted Regulations and New Rulemaking Authorities.


We applaud the Bureau’s openness to receiving public input regarding the substance of the adopted regulations. A robust assessment of these regulations is timely and CBA’s members welcome changes to the rules that will allow them to serve their customers in a more efficient and effective manner. As the BCFP carries out its review, CBA encourages the Bureau to evaluate the adopted regulations in light of its statutory objectives, which are to ensure that:


  • Consumers are provided with timely and understandable information to make responsible decisions about financial transactions;


  • Consumers are protected from unfair, deceptive, or abusive acts and practices and from discrimination;


  • Outdated, unnecessary, or unduly burdensome regulations are regularly identified and addressed in order to reduce unwarranted regulatory burdens;


  • Federal consumer financial law is enforced consistently, without regard to the status of a person as a depository institution, in order to promote fair competition; and


  • Markets for consumer financial products and services operate transparently and efficiently to facilitate access and innovation.


Our comment letter provides specific recommendations below to amend, clarify or eliminate certain provisions of the adopted regulations to enhance the customer experience and improve the functioning of the consumer financial markets.