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

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