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CEI Comments on The Bureau of Consumer Financial Protection’s RIF Regarding Rulemaking Processes

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Introduction
On behalf of the Competitive Enterprise Institute (CEI), we are pleased to provide the following comments on the Bureau of Consumer Financial Protection’s (bureau or BCFP) Request for Information (RFI) regarding rulemaking processes.
Founded in 1984, the Competitive Enterprise Institute is a non-profit research and advocacy organization that focuses on regulatory policy from a pro-market perspective. A strong focus of CEI is on removing regulatory barriers that deny access to capital and credit to businesses, consumers, and investors.
BCFP and the Importance of the Rulemaking Process
The BCFP is simultaneously one of the most powerful and one of the most unaccountable regulators in United States history. It alone has broad rulemaking, supervision, and enforcement powers over nearly every consumer financial product in the U.S. economy.[1] Because of this immense power, an accountable and transparent rulemaking process is critically important to consumers, businesses, and democratic governance.
The bureau’s rulemaking should be

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