Document Type
Article
Comments
This comment letter pre-dates David J. Reiss's affiliation with Cornell Law School.
Abstract
A No-Action Letter reduces uncertainty for Businesses that are attempting to bring legitimate and innovative Products to market. Businesses will rely on these letters and shape their behavior based on them.
At the same time, issuing a No-Action Letter risks encouraging the development of abusive Products if granted with insufficient analysis. Perhaps as importantly, but not as obviously, failing to issue a No-Action Letter at all can also damage consumers by failing to incentivize the development of innovative Products that help consumers. The goal of the Policy should be to balance the promotion of innovation with consumer protection.
Date of Authorship for this Version
12-15-2014
Keywords
United States. Consumer Financial Protection Bureau, No-action letters
Recommended Citation
Lederman, Jeffrey; Rahman, K. Sabeel; and Reiss, David J., "Comment on the CFPB's Policy on No-Action Letters" (2014). Cornell Law Faculty Working Papers. 140.
https://scholarship.law.cornell.edu/clsops_papers/140