–As submitted to the CFPB–
May 21, 2018
Office of the Executive Secretary
Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552
Re: Request for Information (“RFI”) Regarding the Bureau’s Supervision Program (Docket No. CFPB-2018-004)
Dear Ms. Jackson:
Appleseed submits these comments in response to the Consumer Financial Protection Bureau’s (CFPB’s) Request for Information (“RFI”) regarding the Bureau’s Supervision Program. We urge the CFPB not to weaken its supervision program, which is a critical part of the Bureau’s work. CFPB examinations have resulted in enormous benefits to millions of consumers across a number of markets, as well as improvements to the systems and operations of the companies in those markets.
Appleseed is a nonprofit network of 18 Centers dedicated to advancing justice and opportunities that help low-income people and working families build better lives.
Supervision is critical in order for the CFPB to fulfill its mission. It is a complementary tool to the Bureau’s enforcement program, and has the advantages of often being faster, less resource-intensive, and more flexible. Moreover, the Dodd-Frank Act makes clear that it is the CFPB, and not any other regulator, that has exclusive authority to supervise certain entities (i.e., banks with over $10 billion in assets) for consumer protection compliance. The Act is also clear that it requires the Bureau to supervise certain nonbank companies for the consumer protection compliance.
CFPB supervision has greatly improved compliance by supervised entities with consumer financial laws, to the advantage of millions of consumers who are customers or otherwise impacted by those companies. For example:
Finally, the CFPB should continue to issue its Supervisory Highlights reports. The reports provide valuable information, transparency, and guidance to consumers, the general public, the media, and industry itself.
Thank you for the opportunity to submit these comments. If you have any questions about them, please contact Annette LoVoi, Appleseed, Director of Financial Access and Asset Building, firstname.lastname@example.org or 512.633.3535.