In a comment letter to the Consumer Financial Protection Bureau today — the ninth of 12 that the association will submit in response to the bureau’s ongoing feedback initiative — the American Bankers Association encouraged the bureau to update the regulations and related commentaries it inherited from other federal agencies on a regular basis as issues and questions arise and markets evolve.
“Regulations that evolve with consumer needs and market developments, based on feedback from an interested public and relevant data, promote regulatory compliance and innovation,” ABA noted. “Ultimately, consumers benefit through lower prices and better and more choices.”
While ABA did not seek to identify every needed or possible regulatory change, the association focused its comments on a few key priorities. Specifically, ABA called for correction and clarification of fair lending standards under the Equal Credit Opportunity Act regarding disparate impact and the modernization of disclosures in an electronic age. The association also recommended a number of other adjustments to existing regulations to promote compliance and correct impractical or inappropriate requirements.