The Financial Technology Association submitted a comment letter in response to the Consumer Financial Protection Bureau’s (“CFPB” or “Bureau”) proposed rule on Prohibited Contractual Provisions (the “Proposal”). Our members are committed to advancing the responsible use of technology, which significantly improves the industry’s ability to offer innovative financial products while maintaining robust compliance with regulatory standards.
While we share a commitment to protecting consumers, we have serious concerns that this Proposal: (i) violates a number of recent White House Executive Orders; (ii) unnecessarily duplicates existing legal obligations; and (iii) introduces ambiguous and overbroad new prohibitions beyond the Bureau’s authority, lacks a proper evidentiary record, and contains a deficient cost/benefit analysis. For these reasons, we urge the Bureau to rescind the Proposal, which will otherwise harm consumers by limiting choice and access and increasing costs.
Read FTA’s full comment letter here.