Financial Regulatory Reform
ELFA Comment Letter - CFPB Supervisory Designation Proposed Rule (Sept 24, 2025)
On July 21, 2010, President Obama signed into law the Dodd-Frank Wall Street Reform and Consumer Protection Act (P.L. 111-203), which will have important implications for the financial services industry and the equipment finance sector in particular.
ELFA and its Financial Services Regulations Subcommittee of the Legal Committee focused on key policy issues that could directly affect the equipment finance industry: (1) the scope of the proposed Consumer Financial Protection Agency and its potential impact on the small ticket market; (2) the impact of the risk retention rules on the equipment finance syndications market; (3) the impact of the risk retention rules on the equipment finance securitization market; (4) the regulation of nonbank financial institutions and captive finance companies; and (5) the impact of the Equal Credit Opportunity Act reporting provisions. ELFA's objective is to have policymakers recognize the importance of the equipment finance sector to the capital markets and draw appropriate distinctions between the commercial finance sector and other financial institutions and products.
Since its enactment, ELFA has submitted responses to proposed rules from the Executive Branch and will continue to monitor its implementation to protect the interests of the leasing and finance industry.
