Trade Groups to CFPB: Rulemaking Trumps “No Action Letter” Approach

Regulatory uncertainty ultimately harms consumers, because it constrains financial institutions from seeking to develop innovative products. The CFPB's proposal to mitigate uncertainty by providing a letter that it intends to take no action against a particular product has a number of disadvantages over the rulemaking approach. A group of trade associations details these shortcomings in this letter to the bureau. [12/16/14]