Consumer Protection Provisions in Financial Reform Bill Need Fine-Tuning, Says ABA

Letter Sent on Title X of S. 3217, the Restoring American Financial Stability Act of 2010

Several provisions within the Senate’s pending financial reform bill would benefit from further technical improvement, according to a newly issued letter from leaders of the _ Task Force on Financial Markets Regulatory Reform.

The letter, authored by Task Force Chairs William F. Kroener and Giovanni P. Prezioso, addresses administrative and procedural concerns about the structure and powers of the proposed Bureau of Consumer Financial Protection that the bill proposes be established within the Federal Reserve, including:

  • Appointment of the deputy director of the Bureau
  • Size and membership of the Consumer Advisory Board
  • Power to conduct hearings
  • Powers of the Financial Stability Oversight Council

Neither the ABA nor the Task Force has taken a position in favor of or in opposition to the passage of the Act, and the limited scope of the letter and enclosed comments are not meant to imply any endorsement of the Act.

The letter, sent Monday evening to Sens. Christopher Dodd and Richard Shelby, chair and ranking member of the Senate Banking Committee, is linked at:


The ABA Task Force is comprised of 15 prominent financial services lawyers who have served in the top levels of government and private practice. The Task Force includes former general counsels of the U.S. Securities and Exchange Commission, the Federal Deposit Insurance Corporation and the Treasury Department, as well as members and liaisons who have held high-level positions with the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the U.S. Securities and Exchange Commission.  Other members of and liaisons to the Task Force include a founder of Public Citizen Litigation Group and leading academics in the law relating to financial entities and administrative law.  A complete roster is available at: http://meetings.abanet.org/webupload/commupload/CL116000/relatedresources/publicroster.pdf

Additional background or interviews available upon request.

With nearly 400,000 members, the _ is the largest voluntary professional membership organization in the world.  As the national voice of the legal profession, the ABA works to improve the administration of justice, promotes programs that assist lawyers and judges in their work, accredits law schools, provides continuing legal education, and works to build public understanding around the world of the importance of the rule of law.

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