In response to a Request for Information issued in February, the Consumer Bankers Association (CBA) submitted comments to the Consumer Financial Protection Bureau (CFPB) on the matter of external engagements.
“CBA and its member institutions believe that informed, transparent governing is the best way to produce informed policy that is good for both banks and consumers,” CBA Vice President and Associate General Counsel David Pommerehen wrote in a letter to CFPB Acting Director Mick Mulvaney. “A well-functioning Bureau is critical to maintaining a thriving and stable consumer finance marketplace, and it is important that the Bureau, as it has done in the past, does not pursue a seemingly predetermined political agenda to unilaterally shape the public message. To accomplish this, CBA believes greater transparency and openness would uphold the agency as an independent and impartial regulator.”
Among its recommendations, the CBA said the bureau should conduct regular stakeholder meetings for policy considerations, rather than one field hearing per issue. The CFPB should also provide as much information about examination findings as possible while preserving confidentiality. Further, the association believes the CFPB should seek input from its advisory boards on rules in the pipeline, not just finalized rules.
Also, CBA encouraged the CFPB to participate in industry events to keep the flow of information going. In addition, they suggested ending the practice of embargoing important information because it makes it difficult for key stakeholders to present a viewpoint. Finally, CBA said the bureau should not overstate and embellish facts in consent orders and press releases that unfairly damage an institution’s reputation.