Date: December 15, 2014

Issue: Letter to CFPB regarding No-Action Letters


Filing Type: Regulatory

Description: CCMC appreciates the opportunity to comment on the proposed policy of the Consumer Financial Protection Bureau (the “Bureau”) regarding no-action letters.   The Chamber believes that the best way to protect consumers while fostering competition and innovation in consumer financial services markets is to provide companies with clear, well-developed, rules informed by public comment.  If the Bureau believes it needs to changes the rules, we believe strongly that the Bureau should write a rule.  But regulations require interpretation, both by the agency and by market participants, and the Dodd-Frank Act and ensuing rulemakings created numerous new legal requirements that financial services companies must navigate and also shifted responsibility for a broad set of existing statutes and regulations to a new agency.  

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