Date: March 30, 2015
To: Ms. Monica Jackson, Office of the Executive Secretary, Consumer Financial Protection Bureau
Filing Type: Regulatory
Description: The Bureau has expansive authority in the consumer financial services market. But that authority has limits. The Bureau has not observed those limits in regards to agreements between financial services companies and colleges and universities. Instead, it seeks to use pressure and the semblance of authority to extend its influence beyond its statutory mandate. Specifically, the Bureau uses its “Scorecard” to press institutions of higher education (1) to publish agreements with financial services providers regarding any consumer financial services, and (2) to include particular terms preferred by the Bureau in those agreements. The Bureau should allow colleges and universities to decide what will most help their students—decisions that the Bureau has neither the experience, the expertise, nor the authority to second-guess.