rfi

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On July 25, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a “Joint Statement on Banks’ Arrangements with Third Parties to Deliver Bank Deposit Products and Services” to “note potential risks related to arrangements between banks and third parties to deliver bank deposit products and services to end users”.… Continue Reading

The Consumer Financial Protection Bureau (CFPB) issued a Request for Information (RFI) regarding employer-driven debt. Specifically, the CFPB is interested in “debt incurred to an employer or an associated entity, taken on in pursuit or in the course of employment.” Comments must be received by Wednesday September 7, 2022.

The CFPB is seeking input from all workers, including independent contractors and others who are not considered “employees” under the Fair Labor Standards Act.… Continue Reading

Ballard Spahr attorneys have submitted comments to the CFPB in response to its Request for Information Regarding Bureau Rules of Practice for Adjudication Proceedings.

Our comments are based on the extensive experience of Ballard Spahr attorneys in representing bank and non-bank clients in connection with more than 50 CFPB investigations. … Continue Reading

The CFPB has issued a request for information that seeks comment on its handling of consumer complaints and inquiries.  Comments on the RFI must be received by July 16, 2018.

The CFPB defines consumer complaints as “submissions that express dissatisfaction with, or communicate suspicion of wrongful conduct by, an identifiable entity related to a consumer’s personal experience with a financial product or service.” … Continue Reading

We believe the CFPB’s recent RFI on the Bureau’s adopted regulations, which Acting Director Mulvaney discussed during his testimony before the House Financial Services and Senate Banking Committees, provides the prepaid industry an opportunity to persuade the Bureau to reconsider its prepaid rule that was issued in October 2016 and amended in January 2018.… Continue Reading

The CFPB has issued a request for information that seeks comment on its consumer financial education programs.  Comments on the RFI must be received by July 9, 2018.

The CFPB seeks feedback on all aspects of its consumer financial education programs, including the following topics:

  • The CFPB’s focus on specific financial education topics and delivery channels, and its use of technology and contractors
  • Measuring the effectiveness of the CFPB’s financial education programs
  • Avoiding duplication between the CFPB and other federal agencies or other entities

In response to the CFPB’s question asking what financial education topics it should address, we would suggest that the CFPB educate consumers about arbitration, something it has not previously done.… Continue Reading

The CFPB has issued a request for information that seeks comment on its guidance and implementation support.  Comments on the RFI must be received by July 2, 2018.

The RFI lists the following areas of interest on which commenters may want to focus input:

  • Through its “Regulatory Inquiries Function,” the CFPB “assists individual inquirers who have specific questions about the Bureau’s statutes and regulations.” 
… Continue Reading

The CFPB is scheduled to publish notices in tomorrow’s Federal Register that it is extending by 30 days the due dates for comments on its first three requests for information.

According to the notices, the extensions were provided in response to requests from two industry trade groups.  The groups pointed out to the CFPB that all of the other RFIs it has issued have 90-day rather than 60-day comment periods.… Continue Reading

The CFPB has issued a request for information that seeks comment on its rulemaking processes.  Comments on the RFI must be received by June 7, 2018.

The RFI begins with a review of the statutory requirements that are relevant to the CFPB’s rulemaking processes.  The RFI discusses the Administrative Procedure Act notice-and-comment requirements, the Regulatory Flexibility Act requirements for rulemakings that will have a significant impact on a substantial number of small business entities (often referred to as the SBREFA process), federal law requirements for various impact analyses of proposed and final rules, and federal law requirements and MOU agreements for consultation with other federal agencies.… Continue Reading