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Monday, October 13, 2014

CFPB Proposes a "No-Action Letters" Process

By ABIA Outside Counsel, Chrys D. Lemon, McIntyre & Lemon, PLLC

The CFPB has proposed issuing no-action letters for innovative financial products or services in an effort reduce regulatory uncertainty.

In a proposed policy statement, the CFPB indicated that it might start allowing the public to file requests for no-action letters (NALs). These requests would allow the public to ask whether specific financial product or services would either trigger the CFPB staff to initiate an enforcement action or lead to “no-action” from the staff. The CFPB is now soliciting comments about the policy.

“Under the proposed Policy, Bureau staff would, in its discretion, issue [NALs] to specific applicants in instances involving innovative financial products or services that promise substantial consumer benefit where there is substantial uncertainty whether or how specific provisions of statutes or regulations implemented by the Bureau would be applied . . . .”

“A NAL would advise the recipient that, subject to its stated limitations, the staff has no present intention to recommend initiation of an enforcement or supervisory action against the requester with respect to a specified matter.”

The CFPB released its proposed policy on October 10, 2014. The comment period is open for 60 days following publication in the Federal Register.

Read the CFPB Proposed Policy.