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Financial Services Law Insights and Observations

CFPB releases RFI on inherited rules, extends comment period for first three RFIs

Federal Issues RFI CFPB Succession Agency Rule-Making & Guidance

Federal Issues

On March 22, the CFPB released its ninth Request for Information (RFI) in a series seeking feedback on the Bureau’s operations. This RFI solicits public comment to assist the Bureau in deciding “whether it should amend the regulations or exercise the rulemaking authorities that it inherited from certain other Federal agencies.” Specifically, the Bureau is seeking feedback regarding its “Inherited Regulations” – the consumer financial laws that were previously vested in other federal agencies but were transferred to the CFPB assumed by the Dodd-Frank Act. The RFI seeks information related to all aspects of the Inherited Regulations, including (i) whether the Inherited Regulations should be tailored to an institution of a particular size or are incompatible with new technologies; (ii) changes the Bureau could make to the Inherited Regulations to more effectively meet the specific law’s statutory purpose; (iii) changes the Bureau could make to the Inherited Regulations to advance the statutory purposes stated in Section 1021 of the Dodd-Frank Act; (iv) whether the Bureau should introduce pilots, field tests, demonstrations or other activities to better analyze the cost/benefits of potential Inherited Regulations; and (v) where the Bureau could exercise more of its rulemaking authority to better align with the objectives of the applicable consumer financial laws. The RFI is expected to be published in the Federal Register on March 26. Comments will be due 90 days from publication.

On March 19, the CFPB extended the comment period of the first three RFIs released in the series to 90 days (previously covered by InfoBytes here, here, and here). The comment periods were originally set for 60 days after publication in the Federal Register but now the 90-day deadline applies to the following to match those of subsequent issuance: