On September 27, 2022, the CFPB issued a statement through the Federal Register that The Paperwork Reduction Act (PRA) authorization regarding the revised Policy on No-Action Letters and the Policy on the Compliance Assistance Sandbox (Policies) will expire on September 30, 2022. With the expiration of the PRA Authorization, the said policies will no longer be effective on the same date.
The Policy on No-Action Letters set forth how companies should submit No-Action Letter applications and how the CFPB would assess and issue No-Action Letters. The Policy on the Compliance Assistance Sandbox set forth how the CFPB would grant a company immunity from liability under one or more of three safe harbor provisions and provide an approval concluding that the offering or providing of certain aspects of an individual company's product or service complies with the relevant Federal consumer financial law. The CFPB, however, determined that the said policies do not advance the agency’s objective of facilitating consumer-beneficial innovation. Thus, the Bureau will no longer renew the policies' PRA authorizations. It is, however, developing new approaches to facilitate the development of new products and services.
In light of this action, the CFPB will no longer accept No-Action Letter or Compliance Assistance Sandbox applications submitted on a form using OMB Control No. 3170-0059 starting on September 30, 2022.
The CFPB’s Statement on Competition and Innovation can be found here.
