On February 22, 2016, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) published its Final Policy Statement (“Final Policy”) on No-Action Letters (“NALs”). The Final Policy follows a Proposed Policy on No-Action Letters (“Proposed Policy”) that the Bureau published in October 2014. The Bureau received 28 comment letters on the Proposed Policy; however, as discussed below, the Final Policy reflects only minor changes from the Proposed Policy...