CBA Submits Letter on Bureau’s External Engagements

May 29, 2018

WASHINGTON, D.C. – The Consumer Bankers Association today submitted comments on the Bureau of Consumer Financial Protection’s external engagements. The comments are part of the Bureau’s ongoing requests for information.

“CBA and its member institutions believe that informed, transparent governing is the best way to produce informed policy that is good for both banks and consumers,” says CBA Vice President and Associate General Counsel David Pommerehen. “A well-functioning Bureau is critical to maintaining a thriving and stable consumer finance marketplace and it is important that the Bureau, as it has done in the past, does not pursue a seemingly predetermined political agenda to unilaterally shape the public message. To accomplish this, CBA believes greater transparency and openness would uphold the agency as an independent and impartial regulator.”

The letter discusses the following areas:

  • Field Hearings and other Public Forums: The Bureau should conduct regular stakeholder meetings for policy considerations, rather than one field hearing per issue;
  • Supervisory Highlights: These should provide as much information about examination findings as possible while preserving confidentiality, but the findings should not effectively constitute new regulatory obligations;
  • Consumer Advisory Board Participation: The Bureau should seek input from its Advisory Boards on rules in the pipeline, rather than finalized rules;
  • Participation in Industry Events: The Bureau’s participation in industry events is an important part of the flow of information and should continue;
  • Midnight Embargo: The practice of embargoing important information makes it difficult for key stakeholders to present a viewpoint; and,
  • Facts Asserted in Consent Orders & Press Releases for Enforcement Actions: The Bureau should review the previous practice of overstating and embellishing facts in consent orders and press releases that unfairly damage an institution’s reputation and the overall market.

You may read the full letter here.