On Friday, the CFPB launched a new online portal through which the public can submit comments on ongoing efforts to streamline inherited regulations. The move continues the Bureau’s trend of using its website to promote a more interactive and responsive regulatory feel. Over the past few months, the site has hosted dialogs between the Bureau, industry representatives, and consumers as part of Know Before You Owe Campaigns that have targeted disclosures related to mortgages, credit cards, and student loans. CFPB has also positioned its site as its preferred method for receiving and resolving complaints about consumers’ mortgages or credit cards. Indeed, the complaint portals remain the most prominent feature of the CFPB homepage.
The new portal follows up on a December 5 request for public comment on the streamlining of regulations over which CFPB has inherited jurisdiction. For more information on the request, see this blog’s prior coverage by David A. Tallman.
Submission through the portal supplements, rather than replaces, more traditional submission by mail, courier, or electronically by direct upload to regulations.gov. Comments received through the portal will actually be funneled to regulations.gov for the purposes of public recordkeeping. The portal prominently flags the fields that will be transferred with an asterisk. Other fields will not be transferred in full, but the Bureau indicates that it may publish information from those fields in aggregate form.
The portal offers convenience at the expense of flexibility. Whereas commenters submitting by other methods have nearly complete control of the format and content of their message, the portal provides six text boxes. The boxes ask the commenter to identify the regulation and section of the regulation for which a change is suggested, the specific change suggested, the reason for the suggestion, and the effect of the change on each of consumers and financial service providers.
None of the text boxes appear to have a character or word limit, but the format in which the data will be collected nonetheless suggests that the portal would be best utilized for simple suggestions affecting a single regulation. Comments requiring more explanation, or those suggesting more universal changes that may not be attributable to a single regulation, may be better served by traditional methods of comment submission.
Submissions under the original request for public comment were due by March 5, with responses to comments due by April 3. The online portal does not expressly extend those deadlines. It remains to be seen whether the portal will remain online once the comment period has ended, though CFPB’s track record of heavy use of its website suggests that, whether in the current form or not, online portals are likely to be a continuing staple of the Bureau’s interactions with the public.