A trio of organizations recently weighed in on the Bureau of Consumer Financial Protection’s (CFB) request for information on the efficiency of the Bureau’s enforcement of federal consumer financial laws.
The Financial Services Roundtable (FSR), the Consumer Bankers Association (CBA), and the Consumer Mortgage Coalition (CMC) submitted comments regarding the CFB’s efficacy via joint correspondence.
The letter specifically addressed lack of enforcement coordination with other agencies, unclear use of responsible conduct, the past use of press releases to paint a picture of guilt, regulation by enforcement and the length of investigations.
“The Bureau should cease regulating the consumer financial services market by enforcement and reserve its enforcement powers for appropriate circumstances and bad actors,” Richard Foster, FSR senior vice president and senior counsel for Regulatory and Legal Affairs, wrote. “When enforcement action is warranted, the Bureau’s procedures should be efficient, transparent and ensure due process for the institutions and result in a just outcome for consumers.”
CBA officials said its members support financial regulators’ duty to fully enforce the rules and regulations on the book. With that comes the responsibility to ensure enforcement actions are done, when appropriate, in coordination with other agencies, and conducted within an appropriate time frame.
“The Consumer Mortgage Coalition believes that the Bureau needs to coordinate its enforcement efforts with other agencies; ensure that its enforcement actions are defined and completed in a timely manner; and should not be used to get around the rule-writing process,” CMC officials wrote. “Moreover, the practice of using press releases to create an impression of guilt before an investigation is concluded should end.”