WBA recently submitted comments on CFPB’s rulemaking process. In particular, WBA expressed its support of CFPB continuing to convene the Small Business Regulatory Enforcement Fairness Act (SBREFA) panels to obtain insights from experienced bankers concerning the impact of particular proposed regulations. However, WBA cautioned that CFPB needs to ensure it carefully considers the recommendations made by banker panelists. The banking industry was fortunate to have two experienced Wisconsin bankers, nominated by WBA, who were selected to serve on the Mortgage Servicing and HMDA SBREFA panels.
In addition, WBA urged CFPB to provide increase comment periods to give the commenting public as much time as possible to analyze proposed rules and craft thorough and thoughtful comments. In recent years, some of the comment periods have been as little as 30 days. Unless an underlying statute prescribes such a short period of time, WBA supports a lengthier period particularly for complex proposed rules. Finally, WBA also recommended increasing implementation periods, once a rule has been finalized. Read the comment here.