The National Consumer Law Center (on behalf of its low-income clients) (NCLC) and U.S. PIRG submit comments in response to the Consumer Financial Protection Bureau (CFPB)’s Outline of Proposals and Alternatives Under Consideration to Implement Section 1033 of the DoddFrank Act, issued pursuant to Small Business Regulatory Enforcement Fairness Act (SBREFA) on October 27, 2022. The CFPB has requested comment on 149 questions in its Outline of Proposals.
These comments address a limited number of these questions that, as consumer advocacy groups, we believe we have some useful input to offer or would like to indicate our position on a proposal.