CBA Comments on BCFP Inherited Regulations, Rulemaking

June 25, 2018

On Monday, June 25, 2018, CBA submitted comments to the Bureau of Consumer Financial Protection’s request for information on inherited regulations and new rulemaking authorities. In the letter, CBA’s comments focused on the need for the Bureau to ensure rules reflect changes in technology and the ways consumers’ bank. CBA also commented on rules ripe for reform and re-examination.


“CBA greatly appreciates the Bureau’s continued investigation into its own processes and rules, and encourages the Bureau to carefully review the inherited regulations to ensure they stay up to date with changes in technology,” CBA Regulatory Counsel Stephen Congdon wrote in the letter. “Ensuring the financial services industry has workable and tailored rules will help ensure CBA members are able to best serve consumers, and increase consumer financial security.”


The letter makes recommendations for the following issues reaching across multiple inherited regulations:

  • Updating and harmonizing regulations dealing with electronic or digital advertising and disclosures;
  • Amending and clarifying various requirements of the E-Sign Act and modernizing rules governing delivery of disclosures provided electronically; and,
  • Issues binding guidance on Unfair, Deceptive, or Abusive Acts or Practices.


The letter also discusses specific inherited regulations, including:

  • Regulation B: Equal Credit Opportunity Act;
  • Regulation C: Home Mortgage Disclosure Act;
  • Regulation E: Electronic Funds Transfer Act;
  • Regulation F: Fair Debt Collection Practices Act;
  • Regulation G: S.A.F.E. Mortgage Licensing Act;
  • Regulation P: Privacy of Consumer Financial Information;
  • Regulation V: Fair Credit Reporting Act;
  • Regulation X: Real Estate Procedures Act;
  • Regulation Z: Truth in Lending Act; and,
  • Regulation DD: Truth in Savings Act.