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NAFCU urges better cost analysis by CFPB
June 19, 2012 – NAFCU voiced support Monday for the Consumer Financial Protection Bureau's effort to get better information on regulatory impact and compliance costs, but it said meaningful results will require ongoing information gathering as rules are tested over time.
NAFCU Regulatory Affairs Counsel Dillon Shea, in an official comment Monday, said early estimates of compliance costs and burdens are "almost always inaccurate and too low." The only way to get an accurate estimate, he said, "is to revisit the rule after it has been effective for some time."
For example, the CFPB has estimated it will take an institution 90 minutes to respond to questions about this request for information via focus groups, structured interviews and conference calls; and 60 minutes to answer questions delivered via email or through an online survey. Shea said the process is likely to require a "significantly longer" amount of time since the CFPB is looking for qualitative information on potential compliance costs, rules' impact on providers and consumers and the ways in which providers comply with potential regulations.
The best way to minimize the burden of collecting information is to ensure providers are given adequate time to investigate and collect the information sought, he said. "NAFCU would be opposed to any mandatory collection of data."
In other comments, Shea said three of the six credit unions it talked to regarding a similar information request targeting the mortgage and remittance industry said they plan to drop international wire transfers because of the burden associated with the CFPB's recent remittances rule.
"As a general matter, regulations that have the effect of pushing smaller participants from the market should be reconsidered," Shea wrote. As for future mortgage rulemaking, he said, "The Bureau must ensure that the process is calibrated in a way that minimizes the compliance burden for providers and protects against the need for multiple changes to forms, processes and systems."
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