CFPB Publishes Proposed Policy Regarding No-Action Letters

CFPB

On October 10, the CFPB published for comment a proposal for a limited No-Action Letter policy, which appeared in the Federal Register on October 16. The proposed policy aims to “create a process to reduce the regulatory uncertainty that may exist for certain emerging products or services which stand to benefit consumers.” Specifically geared towards financial products and services for which existing statutes and regulations are vague, the proposed policy allows for a CFPB staff member to inform a company that “staff has no present intention to recommend initiation of an enforcement or supervisory action against the requester” by sending a No-Action Letter. The proposed policy requires that the financial product or service that is the subject of a No-Action Letter have substantial consumer benefit when issues of uncertainty regarding certain provisions of statutes implemented by the Bureau arise.