The CFPB wants to get it right the first time. When they come out with the final rules (particularly the Dodd-Frank ones that are out in proposed form right now), they want to fix anything that's a problem with the proposals, deal with any areas where there is a lack of clarity, and address anticipated issues.
To get to that point, banker input is vital. You're the ones in the trenches who can read the proposals and can spot troublesome language.
We know that writing a comment letter is something many of you simply don't have time for -- but it doesn't mean you don't have insights into what's good, what's bad, what might need to be tweaked.
So, we have a plan. In a conversation with the Bureau last week, we pledged to establish a forum in which you can provide your input. We'll have a different thread for each proposal. Tell us what you think is unclear. Point out provisions you believe will have unintended consequences (and tell us what they would be). Explain the practical impact of what's proposed and if you have a suggestion for a better route to achieve the statutory goal, tell us what it is.
We will take the comments and aggregate them. Before the comment deadline for each proposal, we will submit a comment letter on behalf of the BankersOnline community. We're over 50,000 strong -- so we should have a strong voice. This is a way for it to be heard.
Even if you just have a single point to make on a single proposal -- do it. We want to hear what you have to say -- and so does the CFPB. It's in all of our best interests to help flesh these things out. We're going to have to live with the finished product, so we'd better try to shape it into the best end result possible.