In the December 3, 2020, issue of the Federal Register (85 FR 77987), the Bureau of Consumer Financial Protection (Bureau) issued its Advisory Opinions Policy, which sets forth procedures to facilitate the submission by interested parties of requests that the Bureau issue advisory opinions, in the form of interpretive rules, to resolve regulatory uncertainty, which encompasses not only uncertainty with respect to regulatory provisions but also, where applicable, uncertainty as to statutory provisions, and the manner in which the Bureau will evaluate and respond to such requests.

The Advisory Opinions Policy was applicable beginning November 30, 2020 and supersedes the pilot Advisory Opinions Program initiated by the Bureau on June 22, 2020 (85 FR 37331). Advisory Opinions issued by the Bureau under the Advisory Opinions Policy will be published by the Bureau in the Federal Register and on the Bureau’s website at


Full Memorandum