NCBA Requests CFPB Issue Advisory Opinion
NCBA filed a request for an advisory opinion with the CFPB regarding the disclosure of interest and fees on the Model Validation Notice.
The Consumer Financial Protection Bureau’s (CFPB) final Advisory Opinion Policy (AOP) became effective November 30, 2020. The AOP sets forth procedures to resolve regulatory uncertainty for interested parties by filing requests for advisory opinions in the form of interpretive rules.
The CFPB’s procedural rule, provides trade associations with a fantastic opportunity. Trade associations may submit requests for advisory opinions on behalf of its members without disclosing the identity of the member making the request.
After a request from an NCBA member was received regarding the disclosure of interest and fees on the Model Validation Notice, NCBA’s AOP Taskforce thoroughly vetted and approved the inquiry for submission.
NCBA would like to thank the AOP Taskforce members, Barb Nilsen, Blitt & Gaines, Brit Suttell, Barron & Newburger, Amy Mertz Brown, Gurstel Law Firm, Eileen Bitterman, Weltman, Weinberg & Reis and Tomio Narita, Simmonds & Narita for all of the valuable input and guidance they provided.