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NAFCU, trades ask for 90-day comment period on 1033 rulemaking
NAFCU and other financial trade associations Friday wrote to the CFPB requesting the comment period for the notice of proposed rulemaking (NPRM) on section 1033 of the Dodd-Frank Act related to personal financial data rights move from 60 days to 90 days after its publication in the Federal Register. Of note, the selected comment period and deadline is a time typically unavailable for those who observe various holidays in November and December.
“[A] rush to finalize rulemaking, especially after the CFPB has pursued such a deliberate process up to this point, would invite scrutiny and potential future revisions, ultimately creating confusion for consumers and businesses, as well as additional compliance costs,” the groups wrote. “We seek to avoid any confusion or unnecessary future revisions by requesting that the CFPB allow for the necessary time for entities of all sizes to provide duly considered and fully reasoned comments on the NPRM.”
The groups noted the CFPB has previously provided at least 90 days for notice and comment on three different occasions in the seven years it took the agency to propose its formal NPRM. The agency also pursued additional information gathering efforts and agency views through speeches, blog posts, and events.
“[T]he implementation of Dodd-Frank Sec. 1033 is far too important to financial institutions, fintechs, companies, and consumers to rush this rulemaking process at this crucial juncture,” the groups concluded.
NAFCU will continue to work with the bureau on its efforts to balance consumer protections while ensuring a reasonable regulatory environment for credit unions.