CBA Submits Comments on BCFP Guidance & Implementation Support

July 6, 2018

On July 2, 2018, CBA submitted comments to the Bureau of Consumer Financial Protection’s request for information (RFI) on regulatory and rule guidance and implementation support. The 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 


The Bureau's request was the tenth in a series of 12 RFI's released by the agency earlier this year.  CBA has commented on all of the RFIs due thus far and plans to comment on the remaining two by their deadlines.