Date: February 12, 2014
Issue: Regulatory Reform at the CFPB, Write Rules to Make Rules
To: Consumer Financial Protection Bureau (CFPB)
Filing Type: Regulatory
Description: Letter to Director Cordray regarding concerns that the Bureau is not working toward clear, evenly applied, economically sound standards in at least three significant and cross-cutting areas—compliance standards for disparate impact, liability in the context of indirect auto lending, and perhaps other areas as well; the definition of “abusive” acts or practices; and the standard for companies’ liability for the actions of service providers.