The Consumer Financial Protection Bureau should target its rulemaking process more precisely on the consumer harms it seeks to address and do so in a clear, simple and transparent manner, the American Bankers Association said in a comment letter to the bureau today. The letter — the seventh of 12 that the association will submit in response to the bureau’s ongoing feedback initiative — made several specific recommendations to improve the CFPB’s rulemaking.
“The bureau’s rulemaking record to date is best characterized as a series of ambitious undertakings riddled with unintended — but often foreseeable — consequences,” ABA said. “Unnecessarily complex rules promulgated by the bureau have required frequent revision, straining bureau and regulated industry resources and limiting consumer choice and access to financial products and services.”
To mitigate these problems, ABA made several specific suggestions: simplify the overall rulemaking process to avoid frequent and costly follow-up rules; better incorporate feedback from small business review panels; cease using loopholes to evade public scrutiny of its information collections; create a chief economist’s office to conduct cost-benefit analysis; and voluntarily submit to the decennial Economic Growth and Regulatory Paperwork Reduction Act review. For more information, contact ABA’s Shaun Kern.
