In a letter to the Consumer Financial Protection Bureau, the Equipment Leasing and Finance Association is asking the CFPB to expand the recently issued injunction staying the effective dates of Section 1071 of Dodd-Frank to include all affected financial institutions.

This injunction, issued on July 31, currently covers members of the American Bankers Association and Texas Bankers Association and will likely amount to a minimum of a 10-month delay in the compliance deadlines for their members, even if the CFPB prevails in all of the litigation.

The main arguments in ELFA's letter are competitiveness, economics of supporting infrastructure (e.g., software), and the illogic of having institutions that are at the less robust end of the compliance programs spectrum be required to comply first.

The ELFA letter and more information on Section 1071 are available at https://www.elfaonline.org/1071.