Clear Skies Ahead? CFPB Launches Pilot Advisory Opinion Program

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On June 22, the CFPB formally launched a pilot advisory opinion (AO) program (Pilot AO Program) that would allow entities seeking to comply with regulatory requirements to submit a request to the Bureau for an opinion where there maybe uncertainty, such as uncertainty with respect to regulatory or statutory requirements. The Bureau would select topics based on the Pilot AO Program’s priorities and make the responses available to the public. The Bureau recognized that the public as a whole would benefit from a process that provides clarifications broadly and not just to the requesting individuals or entities.

If deemed appropriate, the Bureau will issue an AO based on its summary of the facts presented that would be applicable to other entities in situations with similar facts and circumstances. The AOs would be posted on the Bureau’s website and published in the Federal Register.

Originally published in Non-Prime Times, the official publication of NAF Association, on June 24, 2020.

Please see full Publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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