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Friday, February 19, 2016

CFPB Finalizes Unavailing No-Action Letter Policy

The Consumer Financial Protection Bureau yesterday finalized a policy under which companies may request “no-action” letters indicating that bureau staff have “no present intention” to initiate enforcement or supervisory actions based on a particular product or aspect of a product. The policy is ostensibly aimed at facilitating innovation by providing companies a method for vetting new products for compliance concerns before launching them.

The bureau’s policy, however, does virtually nothing to reduce regulatory uncertainty. The letters would have limited scope and would not be able to be relied upon for compliance; moreover, the bureau envisions granting them only “rarely” and it does not guarantee the confidentiality of proprietary information included in the request.

Read the letter.

Read the ABA/ABIA Letter.