The CFPB’s proposal to reduce regulatory uncertainty for financial innovation through the selective use of “no-action” letters is based on a good idea but is likely to fail to meet its objective unless important changes are made, according to three industry trade groups. For instance, when it comes to submitting requests for a “no-action” letter, the set of products and services to which the bureau’s proposal may apply is difficult to identify, the American Bankers Association, the American Bankers Insurance Association and the Consumer Bankers Association said in a joint comment letter to the regulator. “On the one hand, the proposal requires that the product must not be well established; on the other, it may not cover ‘hypothetical products that ...