CUNA and other organizations called on the Consumer Financial Protection Bureau b comply with its legal obligations under the Small Business Regulatory Act (SBREFA) as part of a proposed rule on credit card penalty payments. SBREFA requires the CFPB to convene and chair a Small Business Review Committee if it is considering a proposed rule that may have an economic impact on a significant number of small organizations.
“The Association would like to reiterate the comments made in our letter to the ANPR, which indicated that any reduction in or elimination of the late payment security port will have a very negative impact on a large number of financial institutions with less than $750 million in assets. (the limit has been raised to $850 million since then),” the letter reads. “Accordingly, if the Agency continues to make laws, as recommended in the Unified Agenda, it must comply with its legal obligations under SBREFA.”
SLEEP reply in August in the CFPB’s Advnce Notice of Proposed Rules Regarding Late Credit Card Bills and Late Payments, said any reduction in or elimination of the late fee safe harbor would have a significant negative impact on a large number of credit unions.
Thby the CFPB’s Unified Rulemaking Agenda released earlier this month up to date the office lists a Notice of the Formation of Laws on these fees, and it is noted by organizations, “due to the significant impact on a large number of small organizations of the law published in the Unified Agenda, the Office must convene a SBREFA panel to assess the impact of any proposed amendment on small entities.”