ARTICLE
30 October 2014

The Uncertain Utility Of A CFPB No-Action Letter

W
WilmerHale

Contributor

WilmerHale provides legal representation across a comprehensive range of practice areas critical to the success of its clients. With a staunch commitment to public service, the firm is a leader in pro bono representation. WilmerHale is 1,000 lawyers strong with 12 offices in the United States, Europe and Asia.
The Consumer Financial Protection Bureau has long sought to promote, rather than prevent, innovation in financial products and services.
United States Finance and Banking

The Consumer Financial Protection Bureau has long sought to promote, rather than prevent, innovation in financial products and services. When Richard Cordray, Director of the CFPB, introduced Project Catalyst, the bureau's effort to foster innovation, two years ago he explained: "We believe that good, consumer-friendly innovation holds great potential for achieving our mission of making the consumer finance market work again for consumers."[1]


[1] Consumer Financial Protection Bureau, Prepared Remarks by Richard Cordray on Project Catalyst: Stimulating Innovation in Financial Products and Services (Nov. 14, 2012), available at http://www.consumerfinance.gov/newsroom/prepared-remarks-by-richard-cordray-on-project-catalyst-stimulatinginnovation- in-financial-products-and-services/. The Bureau has also implemented a trial disclosure policy, which allows companies to apply for a waiver from applicable federal disclosure requirements to test potential disclosure improvements on a trial basis. See Consumer Financial Protection Bureau, Policy to Encourage Trial Disclosure Programs, 78 Fed. Reg. 64,389 (Oct. 29, 2013).


Please click here to read the full text of this article

Originally published on Law360

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More