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.