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Home > ADVOCACY > Where We Stand > Updated CFPA Letter

April 5, 2010

Hon. Charles Schumer (also sent to Hon. Kirsten Gillibrand)
United States Senate
130 South Elmwood Ave, #660
Buffalo, NY 14202

Dear Senator Schumer:

On behalf of the 2,500 employer members of the Buffalo Niagara Partnership, I urge your strong opposition to the current proposal to a form an independent Consumer Financial Protection Agency (CFPA) as passed by the Senate Banking Committee. This legislation, if enacted, will have a deleterious effect on the Buffalo Niagara region’s economy and workforce.

The Partnership strongly agrees that responsibility and accountability must be restored to the financial system. However, the specific proposal establishing the CFPA entails expansive powers over numerous industries that are currently creating sustainable jobs in our region.  CFPA’s authority will extend far beyond banks or bank-like institutions.  It will have the authority to regulate hundreds of thousands of businesses that have little do with consumer finance. Any business that needs access to credit or allows it customers to pay by credit or by monthly installment will face new regulation by the powerful agency, at a time when our nation can ill-afford to add further impediment to doing business. 

The effects of punitive changes designed to mitigate illegal practices by “bad actors” on legitimate job creation and retention must be kept at the forefront of the debate. A specific area of great concern to us is the power given to the CFPA to prescribe rules governing employers’ compensation practices regardless of the wide array of businesses in a vast number of jurisdictions that would fall under CFPA’s oversight. This constitutes another instance of overregulation, as ample state and federal laws already regulate compensation practices.

In addition, rather than adopting a new national standard that eliminates multiple conflicting state laws, the proposed legislation rolls back federal preemption and allows state AGs to bring enforcement actions based on their own interpretations of federal law resulting in a more confusing regulatory environment and fragmented, less competitive markets. In New York’s highly regulated business environment, this would surely lead to a competitive disadvantage for the Buffalo Niagara region. As you are aware, professional and financial services are a growth industry in Buffalo Niagara, and the CFPA as proposed promises to eliminate jobs in this region.

The Partnership applauds your efforts to protect consumers from risky financial practices but, we also feel consumer protection laws must be carefully crafted in a way that enhances consumer protection without allowing the professional and financial services industry and the hard-working individuals they employ to become collateral damage.  I encourage you to bring the dangers of creating a Consumer Financial Protection Agency with excessively broad authority to the attention of your colleagues in the Senate. 

Sincerely,

Andrew J. Rudnick

cc.    Congressman Brian Higgins
         Congressman Christopher Lee
         Congresswoman Louise Slaughter