Overview of the CFPB’s Efforts to Foster Innovation and Provide Guidance to Industry
Author: Eric Goldberg.; Thomas Kearney.
Source: Volume 36, Number 08, August 2020 , pp.93-102(10)
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Abstract:
In 2019, the CFPB rebooted its efforts to encourage the use of its innovation policies. It announced a revised Trial Disclosure Program, a Revised No-action Letter Program, and a new Compliance Assistance Sandbox Program. In 2020, the CFPB announced a pilot advisory opinion policy. The authors discuss these programs, coordination with state regulators, and practical considerations for entities subject to the Bureau’s rules.Keywords: Trial Disclosure Program (“Revised TDP”); No-Action Letter Program (“Revised NAL Policy”);Compliance Assistance Sandbox Program (“CAS Policy”)
Affiliations:
1: Akerman LLP; 2: Akerman LLP.