The CFPB has finalized new policies that lay out when companies are likely to receive no-action letters (NALs) that smooth the path for new product offerings and/or authorize “sandboxes” to ensure that such ventures are fully compliant with CFPB expectations under consumer-protection law and rule. However, the new NAL framework does not apply solely to technology or otherwise innovative products, also providing scope for innovation in existing and established consumer-finance products that may tread on or perhaps even be seen to violate federal standards.
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