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March 28, 2012



Hopefully the CFPB is not going where the US Department of Labor is going and CHANGING regulatory interpretation in its amicus briefs. No way legal and compliance departments can follow regulatory revisions in court briefs!

Steve Van Beek

I'm with you on this one - the CFPB portrayed the H-8(A) form as if it was a regulatory requirement. In fact, it is a PROPOSED model form that hasn't been finalized through the required notice and comment rulemaking process under the APA.

Still not sure what the CFPB was thinking including that reference and model form in their amicus brief and implying it was a requirement.


Creating confusion in favor of consumers despite the safety and soundness concerns to legitimate financial institutions complying with actual regulations. But don't hold me to that!

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