Coalition of State AGs Urge Congress to Limit Federal Agencies Overreach July 12, 2016 On July 11, attorneys general (AGs) from 15 states (AL, AZ, AR, GA, KS, MI, MT, NV, ND, OH, SC, TX, UT, WV, and WI) sent a letter to House and Senate leadership urging them to eliminate “burdensome and illegal” regulations by strengthening the Administrative Procedure Act. The AGs voiced concerns that federal agencies are acting outside their authority by issuing binding rules in the form of guidance documents, while circumventing the notice-and-comment process; failing to consider regulatory costs; and failing to fully consider the effect of their regulations on states and state law. In the letter, the AGs highlighted the Consumer Financial Protection Bureau’s (CFPB) 2013 guidance defining unfair, deceptive, or abusive acts or practices for the collection of consumer debts, which has been used to impose binding requirements and sanctions in practice. The AGs also noted the CFPB’s failure to consult with states regarding their proposed small dollar loan rule, which may conflict with state laws, and pressed Congress to mandate that agencies consult with states when considering regulations that may preempt state law. In conclusion, the AGs urged Congress to take action to ensure federal agencies are in fact providing opportunity for notice and comment for all binding regulatory requirements, acting within their delegated authority, and always rigorously assessing the costs of their regulations.