CFPB, Federal Agencies, State Agencies, and Attorneys General
The CFPB, in a notice published in the Federal Register on September 27, 2022, announced that it was rescinding its No-Action Letter and Compliance Assistance Sandbox policies (Policies). The rescission was effective on September 30, 2022.
In the notice, the CFPB stated:
… Continue ReadingThe CFPB determined that the Policies do not advance their stated objective of facilitation consumer-beneficial innovation.
The CFPB has issued a no-action letter (NAL) to a bank to facilitate the bank’s ability to offer a small-dollar loan product.
In May 2020, the CFPB issued a No-Action Letter Template for small-dollar loan products (Template) offered by insured depository institutions or credit unions subject to the Bureau’s supervisory and enforcement jurisdiction (i.e.,… Continue Reading
In the aftermath of a statement from the CFPB and the four federal banking agencies encouraging small-dollar lending in response to the COVID-19 pandemic and guidance from the four federal banking agencies on “Interagency Lending Principles for Offering Responsible Small-Dollar Loans,” the CFPB has issued a “No-Action Letter (NAL) Template” for small-dollar loan products (SDT) offered by insured depository institutions or credit unions subject to the Bureau’s supervisory and enforcement jurisdiction (i.e.… Continue Reading
The CFPB has finalized its proposed revisions to its Policy to Encourage Trial Disclosure Programs” (TDP Policy) and policy on “no-action” letters (NAL Policy) and has also finalized its proposal to create a new “product sandbox” policy. In addition, the CFPB has announced the creation of the American Financial Innovation Network (ACFIN) to facilitate coordination between the CFPB, other federal regulators, and state regulators and the CFPB’s issuance of the first NAL under the revised NAL Policy. … Continue Reading
A new CFPB blog post titled “An update on credit access and the Bureau’s first No-Action Letter” provides a boost to lenders using alternative data and machine learning in their underwriting models.
The Bureau issued its first (and so far only) no-action letter in September 2017 to Upstart Network Inc.… Continue Reading
“Disclosure Sandbox.” In September 2018, the Bureau proposed significant revisions to its “Policy to Encourage Trial Disclosure Programs” which sets forth the Bureau’s standards and procedures for exempting individual companies, on a case-by-case basis, from applicable federal disclosure requirements to allow those companies to test trial disclosures.
Last week, the CFPB added the following update to its blog post about the proposal:
The original headline [which referred to “companies”] suggested that the proposed Disclosure Sandbox would be open only to “fintech companies.” … Continue Reading
The BCFP has issued proposed revisions to its 2016 final policy on issuing “no-action” letters (NAL), together with a proposal to create a new “BCFP Product Sandbox.” Comments must be received on or before February 11, 2019.
Proposed NAL policy revisions. The revisions are intended to address the 2016 policy’s many shortcomings.… Continue Reading
Much of Director Cordray’s testimony in his appearance before the Senate Banking Committee yesterday consisted of his predictable defense of various CFPB positions. While the hearing was much less contentious than last month’s hearing of the House Financial Services Committee at which Director Cordray appeared, the questions raised by Republican Senators focused on many of the same areas of concern as those of Republican House members.… Continue Reading
