CFPB Requests Information on Adopted and Inherited Regulations
The CFPB has released two additional Requests for Information (RFI), seeking public comment regarding any changes that should be made to the regulations it has previously adopted, including whether new regulations should be issued, as well as concerning regulations and rulemaking authority that the CFPB inherited from other federal agencies.
The RFI concerning previously adopted regulations, available here, generally covers all rules issued by the CFPB after notice and comment, including official interpretations or commentary issued by the CFPB. This RFI does not include the 2015 HMDA rule or the 2017 Payday, Vehicle Title, and Certain High-Cost Installment Loans rule, because the CFPB previously announced their intention to reconsider those rules by engaging in the rulemaking process. Comments are due June 19, 2018.
The RFI concerning inherited regulations, available here, seeks comments concerning regulations that were put in place by other regulators prior to July 21, 2011, and which the CFPB inherited on that date. The CFPB previously sought and obtained suggestions in 2011 and 2012 on how best to streamline inherited regulations, and now plans to review those regulations again. This RFI also seeks comments on rulemaking authority inherited from other federal agencies by order of the Dodd-Frank Act. Comments are due June 25, 2018.
These are the eighth and ninth RFIs in the CFPB’s initiative to reexamine its existing policies and procedures under Acting Director Mick Mulvaney’s leadership. The previous seven open RFIs and their comment due dates (including the dates that have been extended) are:
Civil Investigative Demands (CIDs) – extended to April 26, 2018
Rules of Practice of Adjudication Proceedings – extended to May 7, 2018
Enforcement Processes – extended to May 14, 2018
Supervision Program – due May 21, 2018
External Engagements – due May 29, 2018
Consumer Complaint Database – due June 4, 2018
Rulemaking Process – due June 7, 2018
