March 1, 2011 – Arlington, VA – Ahead of Wednesday’s House Financial Services Committee hearing about the Dodd-Frank Act’s impact on small businesses, the U.S. Chamber of Commerce led more than a dozen business groups in presenting Congress and Treasury Secretary Geithner with six recommendations to guide the development of an effective and transparent Consumer Financial Protection Bureau (CFPB). The Chamber recommendations strike a balance to allow the CFPB to fulfill its consumer protection mandate while ensuring that small businesses continue to have access to credit.

“It is imperative that the CFPB promote polices and regulations that do not stem consumer and business access to capital,” according to Thayer Long, Executive Vice President of the Manufactured Housing Institute. “The manufactured housing industry primarily serves low to moderate income purchasers, and despite the current housing crisis, recent manufactured housing loan performance serves as a fine example of the private sector supporting finance practices that are sustainable over the long term.”

In the letter, the industry-groups offered their support for sound consumer protection regulation that weeds out fraudulent and predatory actors and ensures consumers receive clear and concise disclosures about financial products, but pointed out a number of potential threats to small and Main Street businesses. The letter discusses six recommendations to help address these concerns, and to improve the bureau’s overall effectiveness including:

1. Develop Effective and Efficient Structure to Facilitate Protection of Consumers and Promotion of Economic Growth

• After many agencies failed to act appropriately ahead of the financial crisis, this new bureau must communicate in a way that inspires confidence that it will protect consumers in a uniform manner

2. Empower Consumers by Rationalizing Disclosure Requirements

• The bureau should continue to improve and simplify disclosure across products while not stifling consumer choice of financial products

3. Prevent Duplicative and Inconsistent Regulation of Main Street Businesses

• Compliance is critical, so the bureau must take steps to clarify its requirements and ensure Federal regulators are speaking with one voice

4. Preserve Small Business Access to Credit

• Regulations should not eliminate, or make impractical, the credit products that small businesses rely on for capital.

5. Ensure Coordination with Federal and State Prudential Regulators

• The bureau should involve prudential regulators early and often to ensure proper consideration of safety and soundness issues.

6. Defer Rulemaking Until After Confirmation of a Director

• Issuing rules prior to the Senate confirming a director to the bureau, will prevent Congress from exercising the one avenue for oversight that it expressly retained.

MHI also participated in a March 1st conference call with business and financial industry press in an effort to relay industry concerns with regards to a haphazard approach of implementing these new laws. Specifically, MHI focused on unnecessary and duplicative licensing, the Bureau’s authority to exempt certain businesses, and impeding consumer’s access to credit.

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MHI is the preeminent national trade association for the manufactured and modular housing industries, representing all segments of the industry before Congress and the Federal government. From its Washington, D.C. area headquarters, MHI actively works to promote fair laws and regulation for all MHI members and the industry.