On July 24, 2012, the New America Foundation and the National Consumer Law Center jointly submitted a comment to the CFPB in response to their request for feedback on procedural guidelines proposed by the CFPB to govern the process by which the agency will assume supervisory authority over nonbanks it has reason to believe pose a risk to consumers.

The comment urges the CFPB to provide for greater public disclosure of action taken under the proposed rule and argues that such disclosure would function as a check on the agency to ensure that future directors fulfill their obligation to pursue supervisory authority over nonbanks that are suspected of posing an undue risk to consumers.  It would also represent a means of delivering information regarding potential market risks and traps to consumers.  To read the entire comment, click here.