On September 10, 2019, the Consumer Financial Protection Bureau issued a No-Action Letter Policy, along with a Compliance Assistance Sandbox Policy and Trial Disclosure Program Policy,1 to promote innovation and facilitate compliance in consumer financial services.
This Model No-Action Letter Application includes the following documents:
1. Cover Letter, including a request for confidential treatment under the Freedom of Information Act
2. No-Action Letter application form
3. Draft No-Action Letter language
4. Compliance Assistance Sandbox application form (optional)
5. T rial Disclosure Program application form (optional)
The documents contain [bracketed placeholders] to be completed by the company along with commentary to assist in providing information that will be helpful to the Bureau.
A no-action letter reduces regulatory uncertainty with respect to an innovative product or service through a statement that the Bureau will not bring supervisory or enforcement action against the company for offering the product or service. The Bureau strongly encourages potential applicants to contact the Office of Innovation at email@example.com for informal, preliminary discussion of a contemplated proposal prior to submitting a formal application for a No-Action Letter. We suggest consulting with counsel for advice in structuring the initial discussion with the Office of Innovation.