CSBS, AARMR Offer Guidance to CFPB on ‘Larger Participants’
August 29, 2011
The Conference of State Bank Supervisors and the American Association of Residential Mortgage Regulators jointly provided input to the Consumer Financial Protection Bureau on defining “larger participants” of a market for other consumer financial products or services. Their first main point was that the CFPB ought to pay close attention to state legal definitions of the market, state jurisdictional coverage, and the overall consumer protection priority of the market. Second, the two agencies suggested that, when deciding how to define what entities are “larger,” the criteria and thresholds ought to be flexible, determined on an industry-by-industry basis, and based on aggregated institutional ownership.
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