American Financial Services Association

CFPB Launches Pilot Advisory Opinion Program

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CFPB Launches Pilot Advisory Opinion Program

The Consumer Financial Protection Bureau (CFPB) today launched a pilot advisory opinion (AO) program to publicly address regulatory uncertainty in the Bureau’s existing regulations. In a July 2018 letter to the CFPB on guidance, AFSA asked the Bureau to implement just such a program.

“There is undoubtedly a need for written, explanatory guidance. Written guidance can be a useful tool to help financial institutions obtain clarification on specific practices. With many regulations, particularly long and complex regulations, operational difficulties or unintended consequences arise. In these cases, clarifying guidance is need quickly,” AFSA wrote.

The pilot AO program will allow entities seeking to comply with regulatory requirements to submit a request where uncertainty exists. The Bureau will then select topics based on the program’s priorities and make the responses available to the public.

In addition to the pilot program, the CFPB also announced that the public can comment on the proposed AO program. Following the conclusion of the pilot, the proposed AO program will be fully implemented after a review of the comments received.

June 18th, 2020 by