The Consumer Financial Protection Bureau should consider whether the rules it has written since 2011 are “consistent with the law, clear, and whether they promote the financial interests of consumers in a strong, vibrant, and innovative market that offers the variety of financial products and services that consumers want and value,” the American Bankers Association said in a comment letter to the bureau today. The letter — the eighth of 12 that the association will submit in response to the bureau’s ongoing feedback initiative — outlines the banking industry’s priorities for the reform of several CFPB rules, and offers an extensive set of recommendations for the CFPB to consider as it undertakes its review.
“Since opening its doors on July 21, 2011, the bureau has published sweeping new rules governing remittance transfers, mortgage origination and servicing, prepaid cards, and small-dollar lending,” ABA said. “Given the breadth and complexity of this new body of regulation, it is important to ensure that each rule is working as intended, and it is inevitable that they can be improved, especially with the benefit of experience and hindsight.”
Among other things, ABA called on the CFPB to identify an acceptable replacement for the “GSE patch”; liberalize debt-to-income ability-to-repay/Qualified Mortgage standards; limit the scope of the mortgage servicing rule’s successor-in-interest requirements to cases involving the death of the borrower and exempt borrowers who are debtors in bankruptcy from the live contract and written early intervention notice requirements; and revise the definition of a prepaid account to clarify the distinction between checking accounts and prepaid accounts.