【正文】 than the language deleted from the bill. Requirement of Plain Vanilla Products The revised bill does not include the provision of . 3126 that imposed the plain vanilla product requirement (Section 136). But nothing in the revised bill prevents the agency from imposing that very same requirement， or otherwise pushing consumer products toward standardization， by using its broad authority to prevent abusive acts and practices (Section 131)， which includes the imposition of requirements for the purpose of preventing such acts or practices or by invoking its fair dealing authority (Section 137). Furthermore， the elimination of preemption of State law means that States would be free to impose a plain vanilla requirement even if the agency did not do so， and 50 different such requirements at that. Regulatory Coordination Separating the regulation of financial products from regulatory expertise regarding the safety and soundness of financial institutions threatens consumers as well as the stability of the entire financial system. The vast majority of consumer protection issues also implicate safety and soundness concerns. Frequently， the issues are two sides of the same coin: Pricing a product to reflect its cost and risk may promote safety and soundness but also may implicate consumer protection concerns. The revised bill attempts to address this issue by creating a dispute resolution process. It is not clear whether that process could be effective — even the bill recognizes that it could take 60 days for an issue to be resolved， and experience with statutory deadlines indicates that they are rarely met. More importantly， Section 123(c)39。s regulations on a previously unregulated party and subjecting that party to liability for classactiontype damages. Agency Authority to Expand its Own Jurisdiction Another troubling aspect of . 3126 is that it gives the agency the authority to expand its own jurisdiction. Including within the scope of financial activity any other activity that the agency defines， by regulation as financial activity for the purposes of this title. That opens the door to everexpanding jurisdiction through regulatory fiat and without congressional review. The revised draft includes standards that the agency must meet to expand its authority， but those standards impose no real limitations. The agency need only find that:1. the activity has， or there is likelihood that the activity will have， a material adverse impact on the creditworthiness or financial wellbeing of consumers， 2. the activity is incidental or plementary to any other financial activity regulated by the Agency， 3.the activity39。t previously apply — if they recklessly have participated in a violation of any law. How can these entities protect themselves? Any association with a covered person that engages in wrongful conduct could trigger regulatory obligations that the contractor previously ignored， based on a very vague and uncertain standard. More importantly， that standard can be invoked in an action seeking damages by the agency， a State attorney general， or a plaintiffs39。 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， retailer， 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. For exam