CUNA submitted a letter Monday in response to the Consumer Financial Protection Bureau’s (CFPB) proposal to amend its No-Action Letter (NAL) Policy and create a “Product Sandbox” to facilitate innovation, urging the bureau avoid creating an uneven playing field.
“CUNA highly recommends the Bureau refrain from taking an overzealous approach to innovation that places traditional depository institutions at an unjustified disadvantage,” the letter reads. “Innovation, through technology and other creative solutions, has the potential to enhance the delivery and quality of financial products and services to consumers…CUNA supports the CFPB’s effort to use its authority to encourage innovation through mechanisms like the NAL Policy and Product Sandbox so long as credit unions are given equal access to such programs and any approved programs are limited in number and narrow in scope.”
Other recommendations in the letter include:
Regarding the Product Sandbox, CUNA also urges the CFPB to adopt a group application process.