The Consumer Financial Protection Bureau ("CFPB," now also known as the BCFP) proposed to (i) streamline its no-action letter process and (ii) create a CFPB Product Sandbox.
According to the CFPB, the goals of the proposal are as follows: (i) streamline the application process for filing and review of applications for no-action letters; (ii) expand the types of statutory and/or regulatory relief; (iii) "specify[] procedures for an extension where the relief initially provided is of limited duration"; and (iv) "provid[e] for coordination with existing or future programs offered by other regulators designed to facilitate innovation."
The CFPB also proposed to create a Product Sandbox. The Product Sandbox provides time-limited no-action relief similar to programs administered by other federal regulators, as well as two other forms of additional relief: (a) approvals by order under three statutory safe harbor provisions, and (b) exemptions by order based on a statutory exemption or regulatory exemption.
U.S. Representative Maxine Waters (D-CA), in a statement, criticized the proposal, saying that it could "let bad actors that abuse consumers off the hook entirely from enforcement action by the agency."
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