Compliance Blog

Written by Steve Van Beek

Recently, the Consumer Financial Protection Bureau (CFPB) issued a Notice and Request for Information on specific suggestions for streamlining the regulations it inherited from other regulators (including NCUA).

This request for comment is different than a proposed regulation as the CFPB is seeking feedback on potential changes to the regulations it inherited.  If the CFPB decides to make a change in the future, it would most likely have to go through the full notice and comment rulemaking process to make the change.

The comment period is open for 120 days 90 days (plus 30 days to comment on other comment letters).  NAFCU will be weighing in with our comments.  Over the next weeks, the blog will be analyzing some of the issues the CFPB raised in the Notice.  We will also be mentioning other areas where the CFPB should look to provide clarification or otherwise reduce regulatory burden.  Of course, if you have other ideas or issues that you think the CFPB should address/clarify/streamline - please let us know.   

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There was one item from the Notice that I wanted to share today.  It is the confirmation that the CFPB will indeed reorganize the consumer regulations.  

Reorganization of Regulations

Here is from the notice:

"In the coming weeks, the Bureau will republish the prior agencies’ regulations implementing fourteen consumer laws (the “inherited regulations”) as regulations of the Bureau, which will be codified in Chapter X of Title 12 of the Code of Federal Regulations.  These republished regulations will incorporate only technical changes and will not impose new substantive obligations.  The technical changes reflect the transfer of authority to the Bureau and certain other amendments made by the Dodd-Frank Act to the underlying statutes." 

In the future, Reg Z will no longer be 12 C.F.R. 226 but will be included in the CFPB's section of Title 12 (Chapter X).  The CFPB will send these regulations for republishing in the Federal Register - but there will not be substantive changes at that time.