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CFPB Seeking Comments on Financial Products and Services to Servicemembers
By Lisa C. DeLessio

The Consumer Financial Protection Bureau’s new Office of Servicemember Affairs is at work and seeking information that will undoubtedly be used to focus future regulation and enforcement by the office. On September 6, the CFPB published in the Federal Register a Request for Information on Consumer Financial Products and Services Offered to Servicemembers. The purpose of the notice is information gathering – to assist the office in fulfilling its obligations under Section 1013(e)(1) of the Dodd-Frank Act.

The Dodd-Frank Act requires the CFPB to educate servicemembers and their families to make better informed decisions regarding consumer financial products and services and to monitor complaints made by servicemembers and their families. To that end, the CFPB posed a series of questions in the notice inquiring about the types of products offered to, tailored to, and used by servicemembers. The CFPB also wants to know about benefits that financial service providers extend to servicemembers that exceed protections under the Servicemembers Civil Relief Act and other statutory protections. Benefits of interest include servicemember-specific mortgage modifications, policies and procedures for assisting servicemembers with permanent change of station orders or those who are injured or ill, as well as educational opportunities made available to servicemembers and the effectiveness of those educational opportunities.

The new office will use the comments received to “develop a knowledge base of consumer financial products and services utilized by servicemembers that will inform the office’s planning with respect to education and outreach initiatives, the monitoring of consumer complaints, and other consumer protection measures.”

The comment period was short, with comments due by September 20, 2011. Creditors and servicers that do not provide comments should take this opportunity to consider the questions posed in the notice and take inventory of their own practices. Creditors and servicers should confirm that their policies, procedures, and practices adequately address and comply with federal and state laws applicable to servicemembers and consider whether any changes should be made in light of the potential focus on areas of marketing, education, and accommodations for servicemembers.

Lisa C. DeLessio is a partner in the Maryland office of Hudson Cook, LLP. Lisa can be reached at 410-865-5437 or by email at ldelessio@hudco.com.

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