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ADVISORY OPINION PROGRAM TASK FORCE

NCBA established an Advisory Opinion Program (AOP) Task Force to review and submit members’ relevant questions to the CFPB when seeking an advisory opinion.

The CFPB’s Advisory Opinion program provides that a trade association may submit requests for advisory opinions on behalf of one or more members and those members do not have to be identified.

The CFPB’s Advisory Opinion program focuses primarily on clarifying ambiguities in the Bureau’s regulations, although advisory opinions may clarify statutory ambiguities. Parties may submit requests for advisory opinions regarding any issue under the Bureau’s purview that can be resolved through an interpretive rule.

To have your request reviewed for potential submission to the CFPB, please submit detailed information on your request to [email protected] that addresses the factors established by the CFPB as being appropriate for an Advisory Opinion:

  1. the interpretive issue has been noted during prior Bureau examinations as one that might benefit from additional regulatory clarity;
  2. the issue is one of significant importance or one whose clarification would provide significant benefit; and/or
  3. the issue concerns an ambiguity that the Bureau has not previously addressed through an interpretive rule or other authoritative source.

Please be aware when submitting your request of the following factors that the CFPB has deemed not appropriate for the issuance of an advisory opinion:

  1. the interpretive issue is the subject of an ongoing Bureau investigation or enforcement action;
  2. the interpretive issue is the subject of an ongoing or planned rulemaking;
  3. the issue is better suited for notice-and-comment rulemaking;
  4. the issue could be addressed more effectively through a Compliance Aid or the RIF function; or
  5. there is clear existing Bureau or court precedent that is available to the public on the issue.
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