‘Guidance, implementation support’ RFI generates 45 letters; two (out of 12) remain in series

Forty-five comments on its request for information (RFI) about “Guidance and Implementation Support” were received by the federal consumer financial protection agency as of the close of the comment period Monday, according to tallies provided by Regulations.gov, a web-based application by the federal government supporting its rulemaking process.

The RFI – the tenth in the series of 12 published by the agency – was issued April 2 by the Bureau of Consumer Financial Protection (BCFP, formerly known as the CFPB) for a 90-day comment period. It focused on helping the bureau gather more information about the efficacy of its guidance materials and activities, including implementation support.

In the RFI, the BCFP also indicated it was considering changes to the formats, processes, and delivery methods for providing this guidance. “And it is considering whether it would be appropriate to make changes to the disclaimers used on certain forms of guidance,” the agency stated in April.

The bureau began issuing the RFIs in January in an effort described by agency Acting Director John “Mick” Mulvaney as a “call for evidence” to determine if the agency is fulfilling its job. Two RFIs remain out for comment.

The 45 comments received on the latest RFI represent just 0.05% of the 87,603 comments received on all 12 of the RFIs issued by the agency (including the two still out for comment). The total comments generated for the “guidance and implementation support” RFI is also the second-lowest number of comments received, to date, on one of the 12 RFIs issued.

Three information requests that have closed comment periods dominate the comments generated in the agency’s effort. Those are the RFIs on: agency supervision programs (63% of all comments received), “Public Reporting Practices of Consumer Complaint Information” (27%), and civil investigative demands (9%).

(Note: Since last week, the number of comments for the ninth RFI about “Inherited Regulations and Inherited Rulemaking Authorities” has been revised upward on Regulations.gov. According to the website, 46 comments were added to the tally for the comment period, which closed June 25. The total comments received about the RFI, the website reported, now stands at 84 – the fifth least number of comments received, to date, in the series of RFIs.)

CFPB request for information on its guidance and implementation support

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