The Federal Financial Forum

From: Forbes

Michael Saltsman , Contributor

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FACT: The proposed rule would rescind a controversial 2011 Obama administration regulation that prohibited back-of-the-house employees from receiving tips. This rule was already the subject of extensive legal scrutiny, first challenged by a lawsuit that included an Oregon server (Susan Ponton) who wanted kitchen staff included in her restaurant’s tip pool:

As a result [of the 2011 DOL rule, Ponton] will be prohibited from continuing to enjoy the benefits from this form of a tip pool, including increased camaraderie between front-of-house and back-of-house employees, a higher level of teamwork among the employees and a higher level of service to customers as a result all of which directly results in higher tips for Ponton and the rest of the employees.

The Department of Labor received nearly 400,000 comments on its proposal to authorize the pooling of tips; the overwhelming number of the comments were in opposition to the proposal.

There is an urgent need to supplement the docket with real  world experiences that document the benefits to be achieved from tip pooling. Normally an Interactive Public Docket (IPD) is used to serve this need. Here is an IPD that the Center for Regulatory Effectiveness, CRE, utilized which attracted  nearly a thousand letters–not form letters– from  only one post. There were a number of other posts that received comments in the hundreds.

From: Financial Regulation News

By Dave Kovaleski 

The Consumer Financial Protection Bureau (CFPB) is looking for feedback from the public on the bureau’s enforcement processes.

In a Request for Information (RFI) issued this week, the CFPB said it is seeking information to help assess the overall efficiency and effectiveness of its processes related to the enforcement of federal consumer financial law. The RFI gives the public an opportunity to submit feedback and suggest ways to improve outcomes for both consumers and covered entities.

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