WASHINGTON –CUNA has sent a comment letter to the Bureau of Consumer Financial Protection (BCFP) offering recommendations for improvement to its Rules of practice for Adjudication Proceedings. The letter, signed by Elizabeth A. Eurgubian, deputy chief advocacy officer and senior counsel, was sent in response to the Bureau’s latest Request for Information (RFI) to assess its functions.
CUNA is calling on the Bureau to address following concerns:
- The BCFP should issue a rule mandating that the statutes of limitations for Administrative Adjudications be the same as for federal court proceedings
- Rule 206 governing the Bureau’s file disclosure can be unfair in practice and should be amended
- Rule 110 does not prevent Bureau employees from providing ex parte information to the Bureau Director during the pendency of the adjudication and this should be changed; and
- Rule 119 regarding confidentiality protections is unwieldly and could result in unwarranted disclosure of confidential information.
The full letter can be found in CUToday.info's The Gov here.