At the end of 2020, the Consumer Financial Protection Bureau (“CFPB”) issued an Approval Order under the Policy on the Compliance Assistance Sandbox. The Approval Order allows the applicant, Synchrony Bank, to offer consumers a dual-featured credit card program; a program which begins with a secured credit card account and upgrades upon satisfaction of certain guidelines automatically.
The Compliance Assistance Sandbox allows financial institutions to submit applications upon which the CFPB can, as requested, issue safe harbor from liability under the regulations. Approvals thus facilitate innovation without the regulatory uncertainty.