Last week, the CFPB announced it is requesting specific suggestions for streamlining regulations that were transferred to the agency from other federal agencies. The notice asks the public to identify provisions of the inherited regulations that the agency should make the highest priority for updating, modifying, or eliminating because they are outdated, unduly burdensome, or unnecessary. It discusses several specific requirements that may warrant review, and also seeks suggestions for practical measures to make complying with the regulations easier. Here is the final rule containing a list of the regulations that were transferred to the CFPB.
The notice states that the CFPB is focused on identifying improvements it can make without Congressional action. In setting priorities for streamlining these regulations, the CFPB has set forth five factors it will consider: (1) The potential benefits and costs of a potential regulatory change for consumers and covered entities, (2) the likelihood that the CFPB would be able to achieve the benefits consistent with the underlying statute, (3) the speed with which the public would realize the benefits, (4) the governmental and private resources it would take to realize the benefits, and (5) the state of the evidence with which to judge these factors.
Commenters will have 90 days to comment after the notice is published in the Federal Register, which is expected soon. CUNA will also be posting a Comment Call in the near future and will be working with the Leagues and our Examination and Supervision Subcommittee to develop a response well in advance of the comment deadline that will be shared with credit unions and Leagues. Operation Grassroots will facilitate credit union comment letters to the CFPB.