The Consumer Bankers Association (CBA) offered Monday feedback on requests for information regarding inherited regulations and new rulemaking authorities.
The submission stems from the Consumer Financial Protection Bureau seeking input on the guidelines, with CBA focusing on the need for the Bureau to ensure rules reflect changes in technology and consumers bank methods. CBA also commented on rules ripe for reform and re-examination.
CBA’s correspondence addressed a myriad of recommendations, including updating and harmonizing regulations dealing with electronic or digital advertising and disclosures; amending and clarifying various requirements of the E-Sign Act and modernizing rules governing delivery of disclosures provided electronically; and addressing issues binding guidance on unfair, deceptive, or abusive acts or practices.
“CBA greatly appreciates the Bureau’s continued investigation into its own processes and rules, and encourages the careful review of inherited regulations to ensure they stay up to date with changes in technology,” Stephen Congdon, the CBA’s regulatory counsel wrote in the letter. “Ensuring the financial services industry has workable and tailored rules will help ensure CBA members are able to best serve consumers, and increase consumer financial security.”
CBA’s letter also discussed specific inherited mandates, such as Regulation B: the Equal Credit Opportunity Act; Regulation C: the Home Mortgage Disclosure Act; Regulation E: the Electronic Funds Transfer Act; and Regulation F: the Fair Debt Collection Practices Act.