CBA Submits Comments on BCFP Guidance, Implementation Support

July 2, 2018
Nick Simpson

CBA Submits Comments on BCFP Guidance & Implementation Support


Washington, D.C. – The Consumer Bankers Association submitted comments to the Bureau of Consumer Financial Protection’s request for information on regulatory and rule guidance and implementation support. CBA’s comments focused on ensuring the guidance process is transparent and does not inappropriately circumvent appropriate rulemaking.


“CBA’s members frequently rely on the Bureau’s guidance and implementation support to navigate a complex world of regulations while trying to best serve the financial needs of consumers,” CBA Regulatory Counsel Stephen Congdon wrote. “Establishing procedures for the Bureau to re-examine previously issued guidance will help the Bureau better establish guardrails for the financial services industry … while affording financial institutions the opportunity to better tailor their individual programs to both adhere to Bureau rules and serve consumers.”


To achieve this goal, CBA addressed ways to:


  • Improve the Bureau’s Regulatory Inquiries Function
  • Enhance Compliance Aids Usefulness
  • Formalize and Standardize Official Interpretations and Standalone Rules
  • Better Utilize Fair Lending Guidance and the Division of Supervision Enforcement
  • Improve Other Forms of Written Guidance
  • Modify the use of Disclaimers


Read the full comment letter here.  


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About the Consumer Bankers Association

The Consumer Bankers Association represents America’s retail banks above $10 billion in assets. We advance legislation and promote policies geared toward creating a stronger industry and economy. Established in 1919, CBA’s corporate member institutions account for 1.6 million jobs in America, extend roughly $3 trillion in consumer loans, and provide $270 billion in small business loans. Follow us on Twitter @consumerbankers.