There seems to be a disconnect between CFPB and other Federal agencies in coordinating meaningful federal regulation in this arena. First, CFPB should follow through on it's regulatory initative from last year to revamp Regulation "E", before taking any action regarding just a niche market, as any changes to this regulation would have significant impact the isuance of the types of financial products that could/should be offered/marketed to students enrolled in Institutions of Higher Education (schools).
If other agencies such as the Department of Education, had as its reference, new "Reg E" requirements they could concievably have issued a dear colleague letter by now or possibly suggest regulations of its own requiring any financial products marketed to enrolled students would have to contain these new "Reg E" protections.
Also, FDIC and NCUA may have been able to add perspective as to the new "Reg E" changes impact on consumers and financial institutions alike.
Changes in regulation should not only enhance consumer protections for college students but afford access to those that are either under or unbanked and those not attending a school. CFPB should impact they way all financial products are marketed through out the U.S. They should offer a fair opportunity for the financial entities to make a profit but not through a fee structure that is punative.
IF CFPB will not be issuing new regulation impacting "Reg E" prior to the end of this comment period, perhaps it could provide a link displaying the comments they received in response to their "Reg E" Notice and provide a response to them and how those responses have impact on their present regulatory foray.
Comment on CFPB-2013-0003
This is comment on Notice
Financial Products Marketed to Students Enrolled in Institutions of Higher Education
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