The purpose of this letter is to complement the National Fair Housing Alliance’s comment letter that CRL is a signatory on by focusing on the procedural deficiencies of the cost analysis section of the Notice of Proposed Rulemaking. Specifically, the comment letter highlights that none of the requisite requirements under the Regulatory Flexibility Act, Executive Order 12866, or § 1022(b)(2) have been met. CRL states that the Bureau should withdraw the NPRM and conduct the required analyses before deciding whether to proceed further.
Federal Register :: Equal Credit Opportunity Act (Regulation B)