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TCH Responds to BCFP Request for Information on Its Supervision Program

The Clearing House (TCH) submitted a response to the Bureau’s RFI on its Supervision Program, on which the Bureau sought comment “on how best to achieve meaningful burden reduction or other improvement to the processes used by the Bureau to supervise for compliance with Federal consumer financial law while continuing to meet the Bureau’s statutory and regulatory objectives and ensuring a fair and transparent process for supervised entities.” 

TCH provided a range of specific recommended reforms to the Bureau’s Supervision Program, including the following suggestions:  (i) the examination process should be directed at supervisory activities and objectives, rather than enforcement exercises; (ii) MRAs should be used only to address significant violations of federal consumer financial law (iii) the Bureau should take the lead role in implementing and enforcing federal consumer financial law consistent with the framework established by the Dodd-Frank Act and enhance its coordination with the federal banking agencies; (iv) the Bureau should revise some of its practices with respect to boards of directors; and (v) any Bureau releases that establish new requirements or create policy must be promulgated in compliance with the Congressional Review Act and the Administrative Procedure Act.