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CFPB releases RFI on guidance and implementation materials
On March 28, the CFPB released its tenth Request for Information (RFI) in a series seeking feedback on the Bureau’s operations. This RFI solicits public comment to assist the Bureau in “assessing the overall effectiveness and accessibility of its guidance materials and activities (including implementation support).” Specifically, the Bureau is seeking feedback regarding interpretive rules and general statements of policy that the CFPB determined do not need to go through the Administrative Procedures Act (APA) notice and comment process, as well as other “non-rule guidance” such as compliance guides and webinars. While the Bureau is seeking feedback on all aspects of its various guidance materials, the RFI specifically seeks comments related to (i) the regulatory inquiries function; (ii) regulatory implementation and compliance aids; (iii) official interpretations and standalone interpretive rules; (iv) SEFL guidance materials; (v) disclaimers included on non-rule guidance materials; and (vi) recommendations for new forms of written guidance. The RFI is expected to be published in the Federal Register on April 2. Comments will be due 90 days from publication.