1、中文 3500 字 本科毕业设计（论文） 外 文 翻 译 原文： U.S. Chamber of Commerce The Chamber strongly supports the Administrations goal of enhancing consumer protection. Even before the financial crisis hit， the Chambers Center for Capital Markets Competitiveness called for regulatory reform， including strengthening consu
2、mer protections. The crisis has clearly illuminated the shortcomings of our outdated regulatory system. Millions of consumers and investors were harmed， in part because of regulatory gaps but just as much or even more because of regulators failure to exercise the authority especially the enforcement
3、 authority that they already possess. The Chamber believes that consumers need: 1.Clearer disclosure and better information.2.More vigorous， effective enforcement against predatory practices and other abuses.3.Elimination of regulatory gaps that allowed some financial services entities to escape. re
4、gulation applicable to their competitors. We need smarter， more effective regulation. Adding new regulatory layers and enacting expansive， and duplicative， regulatory authority will not produce that result. Rather， it is likely to lead to confusion， uncertainty， and a regulatory system that imposes
5、heavy burdens on business without providing the protections that consumers need. On September 23， the Chamber released a study conducted by Thomas Durkin， an economist who spent more than 20 years at the Federal Reserve. Durkin concluded that regulatory burdens associated with a lack of preemption a
6、nd legal uncertainties created by new， vague， and undefined statutory terms would reduce the ability of financial institutions to extend consumer credit， and would likely increase the cost of credit that is available. Moreover， this reduction in credit would impact small businesses as well， because
7、it would affect the very consumer financial products that small businesses use to supplement business credit， which often is not available to small and new enterprises. At the very time when we need these job-creators the most in order to restore growth to our economy， we will be hobbling their effo
8、rts by reducing their access to the credit that is essential to fuel that growth. The Chamber opposes the CFPA legislation in its current form because it believes the current bill is the wrong way to enhance consumer protection， and it will have significant and harmful unintended consequences for co
9、nsumers， for the business community， and for the overall economy. Chairman Franks September 22 memorandum identified a number of the specific concerns that we have expressed. However， illustrating the complexity of these issues and the need for careful assessment of the impact of proposed provisions
10、， the changes made in the bill do not address the concerns discussed in the memorandum. Scope The scope of H.R. 3126 as introduced is sweeping， giving the CFPA authority to regulate businesses and professionals far beyond traditional consumer finance. The bill does not focus on entities that are sol
11、ely， or even principally， engaged in financial services activities. Rather， it casts an extremely broad net that would encompass a vast segment of the entire economy. We appreciate the recognition of this overbreadth in Chairman Franks September 22 memorandum. Unfortunately， the revised bill does no
12、t solve the problems created by the underlying bills expansive approach. Here are just a few examples of the many can cite: Merchants and Retailers. Although Section 124(a) provides that the CFPA does not have authority regarding credit or other financial activity issued directly by a merchant， reta
13、iler， or seller of nonfinancial services to a consumer， the definitions of extending credit and covered person remain unchanged， leaving open the possibility that a merchant could be found by the CFPA to indirectly engage in financial activity or to be a material service provider to a covered person
14、. For example， a business that merely accepts credit cards could meet either of those qualifications either indirectly engaging in a financial activity (the provision of credit by the credit card network) or providing a material service to the credit card network. In addition， although businesses th
15、at sell stored value cards are now exempt， businesses that issue stored value cards or that merely allow their names or trademarks to be used on stored value cards remain subject to regulation as a covered person. Accountants ， Lawyers ， and Tax Preparers. Section 124(e) exempts accountants， lawyers
16、， and tax preparers， but provides that the exemption shall not apply . to the extent such person is engaged in a financial activity or is otherwise subject to the existing federal consumer laws. That means that any activity by an accountant or lawyer that falls within the broad financial activity de
17、finition provision of tax planning advice in connection with estate planning， for example or any activity that the agency classifies as a financial activity under its rulemaking authority would trigger the applicability of the statute. Moreover， although tax preparation services are no longer expres
18、sly included in the definition of acting as a financial advisor (Section 101(18)(H)， such services are not expressly excluded from that definition. Accordingly， there is a risk the agency could simply interpret the broad language of the definition (providing financial and other related advisory serv
19、ices) to include tax preparation. Real Estate Brokers and Auto Dealers. The exemptions for real estate brokers and auto dealers suffer from the same flaw as the one for accountants， lawyers， and tax preparers: They do not apply if the person is engaged in a financial activity or otherwise subject to
20、 the existing Federal consumer laws. In addition， even the limited protection provided by the exemptions fails to encompass activities in which these individuals routinely engage. Thus， the real estate broker exemption does not include negotiations relating to financing， and the auto dealer exemption does not apply to lease transactions and excludes activities relating to the arranging of financing. That means that auto dealers likely will be
