Coalition Responds to CFPB Request for Information on Fees for Consumer Financial Products or Services

To Whom it May Concern:

The undersigned financial services trade associations (the Associations) welcome the opportunity to submit this comment in response to the Consumer Financial Protection Bureau’s (CFPB)’s Request for Information Regarding Fees Imposed by Providers of Consumer Financial Products or Services (RFI).[1]

We support the CFPB’s mission “of ensuring that all consumers have access to markets for consumer financial products and services and that markets for consumer financial products and services are fair, transparent, and competitive.”[2] The market for consumer financial products and services is highly competitive.[3] Strong consumer understanding of the cost of credit and other terms of financial products and services—including fees charged with consumers’ consent pursuant to contract and other governing law—is the best means to ensure consumer financial services markets remain “fair, transparent, and competitive.” Clear and conspicuous disclosure of the relevant terms helps foster robust competition in the marketplace, while allowing consumers to shop for and select the product or service that best suits their needs and avoid unnecessary fees.

The Associations have worked constructively with the CFPB (and with the agencies that previously had authority over the statutes transferred to the CFPB after its creation) on numerous rulemakings designed to advance transparency of fees and consumers’ understanding of such fees with respect to nearly every consumer credit product in the marketplace, including those specifically mentioned in the RFI. However, the RFI does not discuss, or even acknowledge, the significant work that both the CFPB and financial institutions have undertaken to advance consumer understanding of the cost of consumer financial products and services, which is an essential back drop to any initiative designed to enhance consumer choice and competition in the marketplace. The Associations stand ready to support evidence-based efforts of the CFPB to increase consumer understanding, consistent with the CFPB’s authority, and urge the CFPB to consider and weigh the views of all stakeholders in the consumer financial services marketplace.

To read the full comment letter, please click here.

[1] 97 Fed. Reg. 5801 (Feb. 2, 2022).

[2] 12 U.S.C. § 5511(a).

[3] See, e.g., (observing that the mortgage market has become even more competitive in the past decade); at 72-73 (discussing “intense competition in the auto finance industry”).