Earlier this year, the Consumer Financial Protection Bureau created a Taskforce on Federal Consumer Financial Law to “examine the existing legal and regulatory environment facing consumers and financial services providers and report to [the Bureau] its recommendations for ways to improve and strengthen consumer financial laws and regulations.” To assist the Taskforce, the Bureau recently issued a request for information, asking the public to submit comments on several topics by June 1, 2020. The Bureau’s request presents a unique opportunity for interested parties to shape recommendations that could lead to a wholesale overhaul of key, federal consumer finance laws.
In its request, the Bureau asks a series of questions about the market for consumer financial products and services, with a particular emphasis on certain markets such as automobile financing, credit cards, consumer reporting, debt collection and settlement, electronic payments, and mortgage origination and servicing. The Bureau groups its questions into a few categories that it hopes will shed some light on how well financial markets are functioning for consumers. Those categories include questions related to:
- Expanding access to financial resources and exploring potential obstacles to financial inclusion;
- Current and future topics regarding protection and use of consumer data;
- Regulations that the Bureau writes and enforces;
- Costs and benefits of overlapping federal and state supervision and enforcement responsibility with respect to financial institutions; and
- Performance of consumer protection.
In its request for information, the Bureau notes that every statutory and regulatory change creates costs for consumers and industries as they adjust to new rules. Thus, the Taskforce is most interested in learning about changes that would provide the most marginal benefits when compared to the marginal costs.