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On behalf of the undersigned trade associations and the thousands of community banks that we represent, we request that the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) extend the comment deadline on the Notice of Proposed Rulemaking (“NPRM”) that implements Section 1033 of the Dodd-Frank Act, to provide community banks with at least 120 days.
There are several factors that we believe warrant the provision of additional time. First, this is a substantial rulemaking that should provide a comment period that reflects the NPRM’s significance. Here, the Bureau published the proposed rule on October 19 and is requiring comments to be submitted by December 29, thereby providing only 70 days for comment.