Richard P. Eckman, chairman of Pepper's Financial Services Practice Group, was quoted in American Banker magazine (subscription required to view the article) on the effect of the Small Business Regulatory Enforcement Fairness Act (SBREFA) on the regulation of consumer financial services.
The Dodd-Frank Act extended SBREFA requirements to the new Consumer Financial Protection Bureau, requiring for the first time that a financial regulator meet with small institutions before proposing any rule that would significantly impact them.
"It's a revolutionary way, certainly in this space, for regulations to be developed," Mr. Eckman said. "The main attraction and the reason SBREFA is special is it gives the small business a unique opportunity to interact with an agency at an early stage of its thinking and help shape the rule."
"So by the time it's proposed, it already has embedded in it the best input the agency can get in how to tailor the rule to minimize the impact on small business."
Pepper was among the first law firms to point out the impact of SBREFA on the CFPB. For more information and analysis, see: