The CFPB has issued its final Advisory Opinions Policy, which allows stakeholders to request interpretive guidance “to resolve regulatory uncertainty.”  While advisory opinions (AO) may address uncertainty in both statutes and regulations, the Bureau states in the Policy that it “will focus primarily on clarifying ambiguities in its regulations.”  The Policy was accompanied by the release of two AOs, one dealing with earned wage access (EWA) products and the other dealing with certain education loan products that refinance or consolidate a borrower’s pre-existing federal, or federal and private, education loans.… Continue Reading