Oppose H.R. 1266, the Financial Product Safety Commission Act of 2015
Advocacy Letter - 09/30/15
Source: The Leadership Conference on Civil and Human Rights
Recipient: House Financial Services Committee
Dear House Financial Services Committee Member:
On behalf of The Leadership Conference on Civil and Human Rights, we write to express our opposition to H.R. 1266, the Financial Product Safety Commission Act of 2015. H.R. 1266 would change the structure of the Consumer Financial Protection Bureau (CFPB) to be led by a commission of five members instead of being led by a single director. H.R. 1266 would weaken the ability of the CFPB to protect consumers from deceptive and abusive financial services practices in an effective and timely manner. We urge you to reject this bill in any form.
The Leadership Conference believes that the abysmal failure of financial regulators prior to the CFPB’s creation to look out for the interests of the communities we represent, or those of consumers in general, has made the need for a strong, independent CFPB perfectly clear. H.R. 1266 would impose a structure for the CFPB that was carefully considered and ultimately rejected during the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act – a bill that was the product of a very open and deliberative process that took place while the lessons of the 2008 financial crisis were still fresh.
H.R. 1266 would bog down the leadership of the CFPB with an additional and unnecessary layer of bureaucracy, increasing the politicization of its decisionmaking process, reducing rather than enhancing its accountability, and making it more difficult for the CFPB to respond and adapt to rapid changes in the financial services industry that have a drastic effect on the financial health of consumers. Dodd-Frank already provided a mechanism by which other independent financial regulatory bodies may oversee and overrule any decisions made by the CFPB, by providing the Financial Stability Oversight Council (FSOC) with the authority to overrule the CFPB. To date, the FSOC has not needed to invoke this authority.
Rather than strengthening consumer protections, H.R. 1266 would put us on the road back toward a regulatory system that failed miserably in the years leading up to our nation’s mortgage crisis. H.R. 1266 represents not just an astonishing refusal to learn from the mistakes of the past, but an insistence on making the very same mistakes all over again.
Again, we urge you to oppose H.R. 1266. Thank you for your consideration. If you have any questions, please contact Rob Randhava, Senior Counsel, at (202) 466-3311.
President & CEO
Executive Vice President