The auto-finance industry and other participants in financial services now have less than 10 days to provide feedback about a draft of legislation to reform the structure and powers of the Consumer Financial Protection Bureau (CFPB).

The U.S. House Financial Services Committee set a deadline of Aug. 21 for the public to answer 17 questions and share other comments about its proposal.

A committee news release broke down the five segments of the draft along with follow-up questions for review.

Title I – Reforming Bureau Governance

Title I reforms the CFPB’s structure and governance. The title brings the CFPB under the congressional appropriations process, reforms the use of civil penalty funds, strengthens cost-benefit analysis and small business impact assessments for rulemakings, requires periodic retrospective reviews of major regulations, and establishes a dedicated CFPB Inspector General.

What additional structural reforms could reduce regulatory uncertainty resulting from changes in administrations and promote a more consistent, predictable, and durable framework for consumer financial regulation?

How could the CFPB improve the quality and transparency of its rulemaking process while maintaining an efficient regulatory framework?

Are there additional reforms to improve retrospective reviews of CFPB regulations to ensure outdated rules are removed?

Title II – Restoring Clarity and Procedural Fairness

Title II provides greater legal certainty by clarifying key statutory authorities, particularly the CFPB’s authority to regulate unfair, deceptive, or abusive acts or practices (UDAAP). Title II also adds procedural safeguards for enforcement actions, clarifies statues of limitations, and addresses jurisdictional boundaries involving attorneys and state-regulated insurance companies.

Are there additional statutory definitions that should be clarified to improve regulatory certainty?

What procedural safeguards best promote fairness and predictability in CFPB supervision and enforcement?

Are there additional areas where Congress should clarify the CFPB’s jurisdiction?

Title III – Promoting Innovation in Consumer Financial Markets

Title III supports innovation and consumer access to financial products and services. The Title provides clarity for certain small-dollar loan products offered by depository institutions and requires agencies to clearly distinguish non-binding guidance from legally enforceable requirements.

What regulatory barriers most limit innovation in consumer financial products and services?

Are there additional changes to regulatory frameworks that encourage more small dollar loan offerings and promote competition and consumer choice?

What further requirements help to distinguish between guidance and binding regulatory requirements?

Title IV – Promoting Effective, Predictable Supervision

Title IV modifies the CFPB’s supervisory framework by adjusting supervisory thresholds for banks and credit unions, allowing certain institutions to elect prudential regulator supervision and examination for consumer compliance, strengthening coordination among financial regulators, and tightening the CFPB’s authority to supervise nonbanks.

How can Congress further improve coordination among the CFPB, prudential regulators, and state regulators?

Are the proposed supervisory thresholds and the supervisory election framework appropriately calibrated?

Are there additional reforms that could make CFPB supervision more risk-based, efficient, and predictable?

How should Congress approach the CFPB’s supervisory and examination authorities to balance effective consumer protection with minimizing duplicative regulatory oversight?

Title V – Preventing Regulation by Enforcement?

Title V reduces reliance on the enforcement process as a means of establishing regulatory policy. The title reforms civil money penalties, market monitoring authorities, indexes regulator thresholds, and improves the CFPB’s complaint procedures.

Are there additional reforms that reduce reliance on enforcement actions to establish regulatory expectations?

How should Congress encourage voluntary compliance and self-reporting while maintaining appropriate accountability?

Are there additional reforms that would improve the CFPB’s complaint process for both consumers and financial firms?

How can Congress best protect sensitive consumer data that the CFPB possesses?

Lawmakers directed the public to send messages about this matter to [email protected].