Joint Trades Response to CFPB RFI on Fees

The undersigned financial services trade associations (the Associations) welcome the opportunity to submit this comment in response to the Consumer Financial Protection Bureau’s (CFPB)’s Request for Information Regarding Fees Imposed by Providers of Consumer Financial Products or Services (RFI). 1 We support the CFPB’s mission “of ensuring that all consumers have access to markets for consumer financial products and services and that markets for consumer financial products and services are fair, transparent, and competitive.”2 The market for consumer financial products and services is highly competitive.3 Strong consumer understanding of the cost of credit and other terms of financial products and services—including fees charged with consumers’ consent pursuant to contract and other governing law—is the best means to ensure consumer financial services markets remain “fair, transparent, and competitive.” Clear and conspicuous disclosure of the relevant terms helps foster robust competition in the marketplace, while allowing consumers to shop for and select the product or service that best suits their needs and avoid unnecessary fees.