This proposal represents the prior CFPB leadership’s attempt to expand its authority beyond the bounds set by Congress by using UDAAP to legislate out of existence widely accepted contract terms. The CFPB also has failed to engage in a meaningful assessment of the benefits to consumers and competition of the contractual clauses it seeks to prohibit. For these reasons, the proposed rule should be rescinded.| www.aba.com
The Consumer Financial Protection Bureau plans to propose rulemaking on small business lending data collection and consumer data sharing before| ABA Banking Journal