On December 13, 2018, the Bureau of Consumer Financial Protection (the “Bureau”) published in the Federal Register a proposed policy (“Proposed Policy”), which would modify its 2016 Policy on No-Action Letters (the “2016 Policy”) and create a new “Product Sandbox” policy in an effort to encourage banks and financial services providers to test new financial products.

PROPOSED NO-ACTION LETTER REVISIONS -

The Proposed Policy is intended to fix several shortcomings of the 2016 Policy and encourage companies to test new financial products and services. The supplemental information published with the Proposed Policy describes changes to the No-Action Letters granted under the 2016 Policy, including...