ABA Comments on CFPB’s Plan for Conducting Regulatory Flexibility Act Reviews

The American Bankers Associatin today wrote to the Consumer Financial Protection Bureau in support of its plan to review rules that have or will have a significant economic impact upon a substantial number of small entities. The purpose of these reviews, which are required under Section 610 of the Regulatory Flexibility Act, is to determine whether such rules should continue without change or be amended or rescinded to minimize their impact.

The CFPB plans to expand its review to regulations that might not otherwise be subject to a Section 610 review to offer additional opportunities to reduce compliance burden on small banks without compromising consumer protection.

ABA recommended that—to the extent possible—the timing of any review be coordinated with any other review or assessment of a particular rule to promote efficiency and effectiveness and to allow any needed changes to be made through a single rulemaking. ABA also urged the bureau to ensure that it has enough staff and allocates adequate resources to gather and analyze data when conducting its reviews.