U.S. Chamber of Commerce Comments on CFPB's Larger Participant Payment Rule

The U.S. Chamber of Commerce’s (“the Chamber”) Center for Capital Markets Competitiveness (“CCMC”) appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau (“CFPB”) regarding its proposed rule Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (the “Rule”). The proposed market would cover providers of funds transfer and wallet functionalities through digital applications for consumers' general use in making payments to other persons for personal, family, or household purposes. Larger participants of this market would be subject to the CFPB's supervisory authority under the Consumer Financial Protection Act (“CFPA”).

The Chamber recognizes the CFPB’s authority under Section 1024 of the Dodd-Frank Act to establish supervisory authority over larger market participants but recommends the CFPB more clearly delineate the market it intends to supervise, further rationalize this expansion of its supervisory authority, and use this supervisory authority without prejudice.