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The Consumer Financial Protection Bureau released its policy statement on No-Action Letters (NALs), ostensibly enabling financial services companies (including fintech startups) to obtain clarity on whether their business models are likely to incur scrutiny from the CFPB.
However, critics argue that the statement does little to provide actual regulatory clarity or comfort, with the CFPB admitting they only expect to receive 1 to 3 NAL requests annually.
The greatest benefit of receiving a favorable NAL is that it would provide comfort to the Applicant that, based on the current model, it is unlikely to become subject to a CFPB enforcement proceeding. In a regulatory environment where the CFPB has demonstrated an aggressive and sometimes creative approach to supervision and enforcement, this type of blessing—as opposed to continued uncertainty—could provide the company with the confidence to continue successful development and growth.
http://www.lexology.com/library/detail.aspx?g=252fe039-e490-4ce5-a410-7d047aef3d7c
