NRMLA Comments on BCFP Guidance and Implementation Support

Financial institutions should not be considered out of compliance if they choose not to follow informal (non-rule) guidance published by the Bureau of Consumer Financial Protection, according to comments submitted by NRMLA this week.

NRMLA responded to a Request for Information published by the BCFP on March 28 that sought public feedback on the overall effectiveness and accessibility of its guidance materials and activities, including implementation support.

“If, and when, the BCFP issues non-rule related interpretations or guidance, it should not take the position that such guidance takes on the force of a rule, and that if industry members do not follow such guidance, they will be out of compliance with the rule that the guidance interprets,” commented NRMLA.

The association also recommended that the Bureau confirm receipt of, and respond more quickly to, requests for clarification and guidance, and suggested that the BCFP publish such responses in writing, so that others may see and benefit from them.

The complete letter is posted to the NRMLA Comment Letters page on NRMLAonline.org, where you can find NRMLA’s comment letters to federal agencies dating back to July 2016. This page is restricted to members only and you must be logged in to view it.