CFPB’s No-Action Letter Policy to Limit New Mortgage Products
March 7, 2016
The CFPB’s recently finalized “no action” policy towards market innovators that come up with new financial services products will probably depress the development of new mortgage loan products, numerous industry legal experts say. Under the policy, bureau staff would issue no-action letters (NALs) to specific applicants, stipulating that the CFPB staff “has no present intention to recommend initiation of an enforcement or supervisory action against the requester with respect to a specified matter.” Also, such a letter could be modified or revoked at any time at the discretion of bureau staff. Further, issued NALs would be publicly disclosed as a general practice, and they would not be binding on the bureau, other regulators or parties in litigation. Former CFPB official ...