Weigh in on the proposals

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.

Thanks for all you hard work.

We welcome your thoughtful comments. "Me too" comments are also appreciated as they add volume and support to another's comments.

It is NOT our intent to specify who made what comments, or identify the bank that person is registered from. But please, this doesn't mean there is a free ride to just voice a criticism. "This proposal won't work, it's nuts" is not helpful. If a proposal doesn't work, why doesn't it. These must be constructive.

You are still encouraged to file your own comment letters as well.

Really good idea... The prospect of writing a comment letter is obviously intimidating to a lot of bankers, but it's an essential part of the regulatory process.

This is an excellent idea. Most of us have so much to do that taking the time to write an individual comment letter is just not feasible. Reading these proposed regs and making comments here for a comment letter will be much more efficient. Thank you!

Great idea.

Fantastic idea! I can't wait to see everyone's comments. It will get all of us thinking!

We really appreciate your support for this effort, but we'd really like to see some comments on the individual proposals. As newer proposals are added by the CFPB (or other agencies), we'll add new threads to this forum.