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Joint Trades Letter re Bureau Supervision Process
May 21, 2018
VIA EMAIL AND COURIER
Office of the Executive Secretary
Bureau of Consumer Financial Protection
1700 G Street NW Washington, DC 20552
Re: Request for Information Regarding the Bureau’s Supervision Program, Docket No. CFPB-2018-0004
Dear Ms. Jackson,
The Financial Services Roundtable,1 the Consumer Bankers Association,2 and the Consumer Mortgage Coalition3 (collectively, the Associations) appreciate the opportunity to comment on potential changes to the Bureau of Consumer Financial Protection’s (the Bureau or CFPB) Supervision Program.
Since the Bureau was established in 2011, its supervisory processes have substantially matured and work relatively well in many respects, however, as described below, there are opportunities to enhance the efficiency and effectiveness of the Bureau’s processes. Chief among these is further enhancing the relationship between the Bureau and the regulated entities, changes that ultimately benefit consumers. The Associations recommend various modifications to the Bureau’s practices to foster working relationships and further our shared objectives of offering financial products and services to consumers that comply with applicable legal and regulatory requirements.
The relationship between the Bureau and industry has also been impacted by a lack of transparency and clarity. The Associations’ members have been encouraged by recent improvements that the Bureau has made in the manner in which examinations have been conducted. However, entities continue to face numerous, unnecessarily burdensome challenges and must devote substantial resources before, during, and after the examination. To assist the Bureau in more fully understanding these challenges, below we address those aspects of the Bureau’s Supervision Program that we view as particularly problematic and offer suggestions for improving the entire examination cycle and eliminating various inefficiencies.