We at CFSI have seen instances where potentially high-quality innovations and products never make it to market because of regulatory concerns. As it stands, the NAL policy is unclear about the level of protection this structure affords, and whether it is enough to provoke and promote innovation. So, while we believe the NAL policy is a step in the right direction, we encourage the CFPB to continue to push the envelope and experiment with other vehicles that would provide even more legal protection and reassurance.

This letter outlines six areas to consider regarding the NAL policy.