No-action letters (NALs) from the Consumer Financial Protection Bureau (CFPB) could enhance innovation and competition in the financial marketplace, the Credit Union National Association believes. In a letter filed with the bureau Monday, CUNA expressed support for the CFPB’s proposed rule but said additional specifics are needed.

The proposal would allow CFPB staff to issue NALs to specific applicants in instances involving “innovative financial products or services that promise substantial consumer benefit where there is substantial uncertainty.” The bureau could send a letter advising the recipient that the CFPB does not presently intend to recommend enforcement or supervisory action involving the matter in question.

CUNA supports the policy and believes NALs “can be a valuable tool for credit unions and others alike,” according to its comment letter, signed by Luke Martone, CUNA’s senior assistant general counsel.

However, CUNA also has concerns that the level of complexity and detail addressed by some of the factors in the proposal may make it “difficult or impossible” for some credit unions to successfully obtain a NAL.

continue reading »