Last week, the American Financial Services Association joined several other groups urging the Consumer Financial Protection Bureau (CFPB) to issue an Advanced Notice of Proposed Rulemaking (ANPR) before it publishes a Notice of Proposed Rulemaking (NPRM) to amend the Fair Credit Reporting Act. AFSA and the other trades are concerned that a rushed, inadequate rulemaking process raises the stakes for dramatic changes to the foundation of the American economy.
The CFPB released its “Outline of Proposals and Alternatives Under Consideration for the Small Business Advisory Review Panel for Consumer Reporting Rulemaking” in September and AFSA submitted comments. However, the outline lacked sufficient detail to enable participants to fully identify and respond to all of the issues and implications at stake. Soliciting input from a wide range of stakeholders will help to ensure that the CFPB understands the impact a potential rule would have on consumers, the American economy, and the businesses, nonprofits, and government agencies that use information to serve the consumers who drive the American economy.
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