Policy Statement on No-Action Letters
Published Date: 1/10/2025
Notice
Summary
Starting January 10, 2025, the Consumer Financial Protection Bureau (CFPB) is rolling out new rules for No-Action Letters (NALs) to encourage real innovation in financial products that help consumers. These letters won’t be given for small tweaks or copycat ideas, and the CFPB will make sure no single company gets a head start by inviting competitors to join in. This means fair play, fresh ideas, and smarter use of government resources for everyone involved.
Analyzed Economic Effects
9 provisions identified: 3 benefits, 6 costs, 0 mixed.
NALs only for real unmet needs
If you apply for a CFPB No-Action Letter, you must show your product or service solves an unmet consumer need — simply increasing access or making a minor tweak is not enough. The CFPB says letters are for innovations that address real consumer problems rather than repackaged or gap-exploiting versions of existing products.
No single‑firm topics; competitors invited
The CFPB will not approve a No-Action Letter on a topic for a single firm and will affirmatively invite the applicant's competitors to apply for the same topic so no company gets a first-mover advantage. This means firms cannot receive a topic-specific NAL that only they are allowed to rely on.
Enforcement‑history ineligibility for 5 years
The CFPB will not consider No-Action Letter applications from companies that were the subject of an enforcement action for violations of Federal consumer financial law in the last 5 years, or that are subject to a pending enforcement investigation. This is an explicit five‑year lookback rule.
NAL duration, modification, and rescission rules
A No-Action Letter will expire in 2 years and will be automatically rescinded if the recipient materially changes the product or service so it no longer fits the application, unless an amended NAL is approved. Recipients may apply for modifications, and the CFPB expects to grant or deny complete modification applications within 30 days; the CFPB may allow a six‑month wind-down before termination unless consumer injury requires a faster stop.
Supervision consent and legal risks for applicants
Recipients must consent to the CFPB's supervisory examination authority if they are not already subject to it. Also, submitting false or misleading information in an application may violate federal law (18 U.S.C. 1001) and trigger prosecution.
No marketing or promotion of NAL status
If your product receives a No-Action Letter, you may not market or promote that fact because the CFPB says such promotion creates the false impression that the agency endorses the product. The prohibition is intended to prevent misleading consumers about the CFPB's views.
Public posting and 60‑day comment period
The CFPB will post No-Action Letter applications to regulations.gov and accept public comment for 60 days. Applications and published materials will follow confidentiality protections in the policy.
Former CFPB attorneys generally barred
The CFPB generally will not consider No-Action Letter applications from former CFPB attorneys representing companies as outside counsel, to avoid ethical conflicts and the appearance of special treatment. This is a discretionary bar the CFPB intends to apply generally to such outside counsel.
CFPB will publish NALs and may publish denials
The CFPB intends to publish No-Action Letters and the associated application on its website, and it may publish denials (with redactions where appropriate). The CFPB will follow confidentiality law (including FOIA Exemption 4 and its Disclosure Rule) when handling confidential business information.
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