Comment on CFPB-2011-0022-0001

Docket No. CFPB-2011-0022 Madam Secretary, In Section III, Subsection B, the BCFP analyzed whether notice-and-comment are necessary for promulgation of this regulation. I was interested to note that the BCFP determined there was good cause to forego APA procedure as unnecessary and contrary to public interest in light of the lack of substantial change from the regulation’s original form. I fail to see how allowing the public and stakeholders the opportunity to comment, even on minimally important matters such as nomenclature, can be against public interest. The only argument included in the rule is the time such endeavors require. This argument sounds like the BCFP is less concerned for the public’s interest, than its own. My suggestion is to remove the references to public interest as an argument for bypassing the APA requirements regarding this rule. The argument appears in only two places in the regulation. For your benefit, I have suggested rewording: Location: Section III, Subsection B, Paragraph 1; “The Bureau finds that there is good cause to conclude that providing notice and opportunity for comment would be unnecessary and contrary to the public interest under these circumstances.” Suggestion: “The Bureau finds that there is good cause to conclude that providing notice and opportunity for comment would be unnecessary under these circumstances.” Location: Section III, Subsection B, Paragraph 2; “Using notice-and-comment procedures would delay this process and thus be contrary to the public interest.” Suggestion: As this sentence does not resolve a problem posed in the prior sentence (or elsewhere in the regulation), I suggest this sentence be struck in its entirety. Kind Regards, Amy Lane