FSR, CBA, CMC Submit Comments on Bureau Enforcement Process

FSR's picture

When enforcement action is warranted, the Bureau's procedures should be efficient, transparent and ensure due process for the institutions and result in a just outcome for consumers.

FSR, CBA, CMC Submit Comments on Bureau Enforcement Process​

FSR, CBA, CMC Submit Comments on Bureau Enforcement Process


WASHINGTON – Financial Services Roundtable (FSR), the Consumer Bankers Association (CBA), and the Consumer Mortgage Coalition (CMC) today submitted comments to the Bureau of Consumer Financial Protection’s request for information on the effectiveness and efficiency of the Bureau’s enforcement of federal consumer financial laws. The request also asked for information detailing any appropriate changes to the process.

“CBA members support financial regulators’ duty to fully enforce the rules and regulations on the book,” CBA General Counsel and Executive Vice President Steve Zeisel said. “With that comes the responsibility to ensure enforcement actions are done, when appropriate, in coordination with other agencies, are clearly defined, and conducted within an appropriate timeframe. It is also vital for the Bureau to stop the practice of using enforcement actions to circumvent the rule-writing process and issuing press releases to create an illusion of guilt before a conclusion has been reached.”

The Bureau should cease regulating the consumer financial services market by enforcement and reserve its enforcement powers for appropriate circumstances and bad actors,” said FSR Senior Vice President and Senior Counsel for Regulatory and Legal Affairs, Richard Foster. “When enforcement action is warranted, the Bureau’s procedures should be efficient, transparent and ensure due process for the institutions and result in a just outcome for consumers.”

“The Consumer Mortgage Coalition believes that the Bureau needs to coordinate its enforcement efforts with other agencies; ensure that its enforcement actions are defined and completed in a timely manner; and should not be used to get around the rule-writing process.  Moreover, the practice of using press releases to create an impression of guilt before an investigation is concluded should end.”

The joint letter specifically addressed lack of enforcement coordination with other agencies, unclear use of responsible conduct, the past use of press releases to paint a picture of guilt, regulation by enforcement, and the length of investigations.

About The Author

FSR Newsroom

The Financial Services Roundtable represents the largest integrated financial services companies providing banking, insurance, payment and investment products and services to the American consumer. Member companies participate through the Chief Executive Officer and other senior executives nominated by the CEO. FSR member companies provide fuel for America’s economic engine, accounting for $92.7 trillion in managed assets, $1.2 trillion in revenue, and 2.3 million jobs.

Suggested Reading

BCFP Should Recalibrate Civil Investigative Demand Process to Enhance Transparency and Efficiency​

April 27, 2018

At times, the Bureau has wielded its considerable investigation powers without first considering alternative and more tailored approaches and without sufficient regard for the impact on regulated entities, the long-term impact on the consumer financial marketplace, or the opportunity costs of the Bureau’s use of enforcement resources.

FSR Welcomes Treasury Recommendations to Update the Community Reinvestment Act​

April 3, 2018

Treasury’s report includes many common-sense recommendations to ensure banks are meeting the needs of American consumers and communities across the country.

“This industry provides vitally important services to nearly every American – every day.  Affordable access to financial services is key to growing the American economy and fueling the American dream.”  -Chris Feeney, FSR CEO


Financial Services Roundtable is the leading advocacy organization for America’s financial services industry. For updates, sign up below ↓

Copy this html code to your website/blog to embed this press release.


Post new comment

9 + 2 =

To prevent automated spam submissions leave this field empty.