WASHINGTON—In response to the CFPB’s release of an outline of proposals under consideration for the Bureau’s rulemaking effort related to the Fair Credit Reporting Act (FCRA), NAFCU, CUNA and other trade groups are calling on the Bureau to follow the “proper process and issue an advance notice of proposed rulemaking (ANPR)” before moving forward with a proposed rule.
“A rushed, inadequate rulemaking process raises the stakes for dramatic changes to the foundation of the American economy,” the groups wrote.
In a letter to the Bureau, the groups outlined four reasons they believe the Bureau to issue an ANPR first, including:
- Soliciting the widest range of stakeholder input before making substantial changes to Regulation V that would “overhaul the rules that undergirds the American credit economy”
- Building on comments received through the Small Business Regulatory Enforcement Fairness Act (SBREFA) review process to offer more specificity about the regulatory changes under consideration and allow input from a wider array of interested parties
- Understanding the impact of and intersections between the bureau’s section 1033 rulemaking – which is in the notice of proposed rulemaking stage – and the FCRA rulemaking
- Aligning the process with other rulemakings for complex regulations that have significant impacts on the American economy
Increased ‘Understanding’
“An ANPR process could increase the Bureau’s understanding of the impacts its rule would have on consumers, the American economy, and the businesses, nonprofits, and government agencies that use information to serve to consumers drive the American economy,” they concluded.
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