In a comment letter to the Consumer Financial Protection Bureau today – the fifth of 12 the association will submit as part of the bureau’s ongoing feedback initiative — ABA and 51 state bankers associations highlighted how changes to the bureau’s approach to external engagements could improve the rulemaking process.
“Experience has shown that the bureau rulemakings have lacked clarity or created market impacts that has not served consumers well,” the groups pointed out, citing as an example the bureau’s mortgage rules, which have undergone a total of 31 revisions. While these changes were necessary, “[m]uch of the difficulty could have been avoided if the bureau had not significantly discounted much of the feedback offered by stakeholders earlier in the rulemaking process,” the associations said.
The groups encouraged the bureau to engage stakeholders early in the rulemaking process and to communicate with external stakeholders in a way that is fair, balanced and builds trust. Specifically, the CFPB should maximize the value of its advisory councils and committees, including the Consumer Advisory Board and Community Bank Advisory Council; structure its outreach meetings to inform policy and regulations; treat industry meetings as opportunities and not merely as procedural obligations; and enhance its outreach to the vendor community.
