NCLC joined comments urging the CFPB to fundamentally rewrite its draft Strategic Plan to reflect a vision that proactively and aggressively defends ordinary people while ensuring fair, transparent, and competitive financial markets. The draft plan presumes that consumer protection regulation is an “unwarranted burden, retreats from non-bank supervision, narrows the definition of actionable harm, de-emphasizes civil penalties, and signals a reluctance to keep pace with market developments. Collectively, the draft plan points toward a Bureau that will be radically less protective of consumers than Congress mandated in 2010.
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