ELFA Asks CFPB to Apply Section 1071 Judicial Delay to All Members



In a letter to the Consumer Financial Protection Bureau, the Equipment Leasing and Finance Association asked the bureau to expand a recently issued injunction staying the effective dates of Section 1071 of the Dodd-Frank Act to include all affected financial institutions.

This injunction, issued on July 31, currently covers members of the American Bankers Association and Texas Bankers Association and will likely amount to a minimum of a 10-month delay in the compliance deadlines for their members, even if the CFPB prevails in all of its litigation pertaining to its funding structure.

The main arguments in the ELFA’s letter are based on competitiveness, the economics of supporting infrastructure (e.g., software), and the illogic of having institutions that are at the less robust end of the compliance programs spectrum be required to comply first.


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Terry Mulreany
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