BPI submitted a comment letter related to the Consumer Financial Protection Bureau’s Consumer Financial Law Taskforce, supporting the continued efforts of the taskforce and encouraging the taskforce to engage in modernization practices related to certain efforts. BPI encourages the CFPB to focus on (i) modernizing consumer disclosures so that they serve consumers who increasingly choose to operate in a digital world, (ii) using the experience of the COVID-19 pandemic to modernize regulatory requirements to provide more flexibility so that firms can more readily meet consumer needs in times of crisis, (iii) steps to modernize credit underwriting to enhance opportunities to use alternative data and artificial intelligence/machine learning models to refine credit underwriting and promote access to responsible credit, (iv) institutionalizing constructive changes made to its supervision process and (v) implementation of certain changes to its enforcement policies to make the process more fair, transparent and consistent.
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