CSBS Issue Briefings - January 2020

CSBS ISSUE BRIEFING

In our comments on the proposed policies, we asked the CFPB to clarify that participation in the Product Sandbox does not provide a safe harbor from state enforcement of federal consumer law just as it does not exempt an entity from state consumer protection laws. Following the finalization of the policies, the CFPB held a briefing call for state regulators on Tuesday, Sept. 24, 2019. In response to questions on the call, the CFPB reaffirmed its belief that the safe harbor provided via sandbox relief would prevent states from taking action against an entity within the sandbox. Talking Points • State regulators oppose the preemption of state enforcement authority via the creation of the CFPB’s proposed sandbox. • State regulators are independently empowered to enforce the statutory provisions of federal consumer financial law within their respective states.

SME Contact: Daniel Schwartz, Director, Policy Development: (202) 728-5742, Dschwartz@csbs.org

Date Updated: 01/13/2020

FOR STATE REGULATOR USE ONLY