The CFPB has issued its final Advisory Opinions Policy, which allows stakeholders to request interpretive guidance “to resolve regulatory uncertainty.” While advisory opinions (AO) may address uncertainty in both statutes and regulations, the Bureau states in the Policy that it “will focus primarily on clarifying ambiguities in its regulations.” The Policy was accompanied by the release of two AOs, one dealing with earned wage access (EWA) products and the other dealing with certain education loan products that refinance or consolidate a borrower’s pre-existing federal, or federal and private, education loans.… Continue Reading
Having announced earlier this year that it was implementing an advisory opinion (AO) program, the CFPB published a procedural rule in today’s Federal Register establishing a pilot AO program. It also published a proposed procedural rule in today’s Federal Register that would establish an AO program to replace the pilot program.… Continue Reading
The Congressional Budget Office (CBO) recently released a cost estimate for H.R. 4662, entitled the “Bureau Advisory Opinion Act.” This was part of series of bills reported in June 2014 by the House Committee on Financial Services that were intended to promote greater transparency and accountability at the CFPB.
H.R.… Continue Reading