AFSA Responds to CFPB’s Interim Final Rules

On Sept. 26, AFSA submitted one comment letter to the Consumer Financial Protection Bureau (CFPB) in response to four interim rules issued by the CFPB that would establish procedures for: (1) the conduct of adjudication proceedings, (2) investigations pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act), (3) governing the process by which state officials notify the CFPB of actions or proceedings undertaken to enforce the Dodd-Frank Act, and (4) the public to obtain information from the CFPB under the Freedom of Information Act, the Privacy Act of 1974, and in legal proceedings. The latter also establishes the CFPB's rules regarding the confidential treatment of information obtained from persons in connection with the exercise of its authorities under federal consumer financial law.

 

AFSA stated its concern that the interim final rules do not sufficiently account for the adequacy and enforcement of existing state laws and regulations under which regulated entities operated before new regulatory obligations were imposed. “Furthermore, we are concerned that the Bureau’s stated commitment to efficiency may inhibit appropriate due care being given to matters under its jurisdiction,” AFSA wrote.