NAFCU writes to CFPB regarding 2022-2026 Strategic Plan

NAFCU Senior Regulatory Affairs Counsel Kaley Schafer Monday sent a letter to the CFPB in response to the bureau’s strategic plan for fiscal year 2022-2026. The CFPB first issued its proposed strategic plan in December 2021, detailing four strategic goals that will be carried out by various objectives.

The CFPB’s first goal is to implement and enforce the law to ensure consumers have access to fair, transparent, and competitive markets that serve consumers’ needs and protect consumers from unfair, deceptive, and abusive acts and practices (UDAAP), and from discrimination. In the letter, NAFCU urged the CFPB to “initiate a rulemaking to define the ‘abusiveness’ standard, or, alternatively, reinstate its previous policy statement clarifying the standard.”

Regarding the bureau’s objective to focus on supervision and enforcement resources to those that pose the greatest harm to consumers, the association supports this focus, but points out that size of an institution does not equate to risk. The CFPB should instead, “divert supervision resources to those actors or products that cause the greatest harm to consumers and are in violation of federal consumer financial laws,” suggested Schafer.

Schafer also encouraged the CFPB to remove or revise obsolete regulations to help credit unions deal with increased compliance burdens and increased compliance costs, which would allow them to focus more on serving their members. “Revising and removing outdated and conflicting regulations may better align with industry practices and consumer expectations, while simultaneously ensuring consumer safety,” noted Schafer.


continue reading »