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B-329129 1 (2017-12-05)

handle is hein.gao/gaobaduas0001 and id is 1 raw text is: GAOU.S. GOVERNMENT ACCOUNTABILITY OFFICE 441 G St. N.W. Washington, DC 20548 B-329129 December 5, 2017 The Honorable Patrick J. Toomey United States Senate Subject: Bureau of Consumer Financial Protection: Applicability of the Congressional Review Act to Bulletin on Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act Dear Senator Toomey: You asked whether a Bulletin issued by the Bureau of Consumer Financial Protection (CFPB or the Bureau) on March 21, 2013, on Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act1 is a rule for purposes of the Congressional Review Act (CRA).2 CRA establishes a process for congressional review of agency rules and establishes special expedited procedures under which Congress may pass a joint resolution of disapproval that, if enacted into law, overturns the rule. Congressional review is assisted by CRA's requirement that all federal agencies, including independent regulatory agencies, submit each rule to both Houses of Congress and to the Comptroller General before it can take effect. For the reasons discussed below, we conclude that the Bulletin is a general statement of policy and a rule under the CRA.3 1 CFPB Bulletin 2013-02 (Mar. 21, 2013) (Bulletin). 2 CRA was included as part of the Small Business Regulatory Enforcement Fairness Act of 1996, Pub. L. No. 104-121, subtitle E, 110 Stat. 857, 868 (Mar. 28, 1996) codified at 5 U.S.C. §§ 801-808. 3 Our practice when rendering opinions is to contact the relevant agencies and obtain their legal views on the subject of the request. GAO, Procedures and Practices for Legal Decisions and Opinions, GAO-06-1064SP (Washington, D.C.: Sept. 2006), available at http://www.ao. rov/roductsGAO-06-1064SP. We contacted the General Counsel of the CFPB who provided us with the Bureau's views. Letter from CFPB to Assistant General Counsel, GAO, July 7, 2017.

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