CUNA strongly urged the Bureau of Consumer Financial Protection to employ a greater use of advance notice of proposed rulemakings (ANPRs) Thursday. CUNA sent a copy of its comprehensive white paper to the bureau in response to its request for information on the bureau’s rulemaking process.
“As future bureau rules, including the small business lending rule, lack a statutorily required or set implementation timeline, we strongly urge the bureau to employ greater use of ANPRs rather than only using the Notice of Proposed Rulemaking (NPR) process,” the white paper reads. “An illustrative example of rulemaking that would have benefited from more external stakeholder engagement before moving forward is the bureau’s payday and small dollar lending rule.”
CUNA’s white paper also recommends the bureau: