The National Association of Federally-Insured Credit Unions (NAFCU) was among several industry trade associations that offered feedback on the Consumer Financial Protection Bureaus (CFPB) request for information (RFI) on so-called “junk fees” – fees that are added on to consumer financial products and services.
The CFPB intends to use responses from the RFI to help with “enforcement, supervision, regulatory, and other authorities to create fairer, more transparent, and competitive consumer financial markets.”
The group — which includes NAFCU, American Bankers Association, Consumer Bankers Association, Credit Union National Association, and Independent Community Bankers of America, the name a few – offered a list of their concerns in a letter to the CFPB.
Specifically, they said the CFPB must consider the current regulatory regime and significant body of existing data concerning consumer understanding of consumer financial products and services. They added that fees in the consumer financial services market are subject to significant disclosure requirements to promote consumer choice and competition. Further, they add that the RFI fails to consider the bureau’s extensive research and previous rulemaking to assess and advance consumer understanding of fees. Finally, they said any policy interventions must be grounded in the bureau’s authority.
“The CFPB is charged with ensuring that ‘consumers are provided with timely and understandable information to make responsible decisions about financial transactions,’” concluded the groups. “If the CFPB now asserts that its past rulemaking efforts have failed to achieve that objective, it must square that assertion with the actual evidence, much of which is already available to the CFPB. If, based on such evidence, the CFPB determines that policy intervention may be warranted, it should proceed in a fair and impartial manner, grounded in its authority, and in coordination with other relevant agencies.”