CFPB Issues Proposed Revisions to No-Action Letter Policy and Proposes to Create a Product Sandbox

Written by Gary Bronstein, Sam Arora, Michael Breslin and Eamonn Moran

The Consumer Financial Protection Bureau (CFPB or Bureau) has issued proposed revisions to its 2016 final policy on issuing No-Action Letters, along with a proposal to create a new Product Sandbox.

The Bureau proposed its Policy on No-Action Letters in October 2014 and finalized it in February 2016. The 2016 Policy provides for the issuance of No-Action Letters consisting of non-binding staff-level no-action recommendations. The Bureau has issued only one such No-Action Letter to date. In the Bureau’s view, “this strongly suggests that both the process required to obtain a No-Action Letter and the relief available under the 2016 Policy have not provided firms with sufficient incentives to seek No-Action Letters from Bureau staff.” Accordingly, the Bureau states that it is seeking comment on a number of changes to the 2016 Policy that would address these issues and “bring certain aspects of the Bureau’s policy more into alignment with no-action letter programs offered by other federal regulators.”

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