comment letter

CBA Letter in Support of the “Rectifying UDAAP Act”

LINDSEY JOHNSON
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Dear Congressman Barr:

On behalf of the Consumer Bankers Association (CBA), I write to express our support for H.R. 6789, the Rectifying UDAAP Act. Reforming the Consumer Financial Protection Bureau’s (CFPB or Bureau) unfair, deceptive, and abusive acts or practices (UDAAP) authority is critical for ensuring transparency by the Bureau and adherence to high regulatory standards for depository institutions.

Treating customers fairly and closely following consumer protection laws are core to banks’ business models and customer relationships and are practices banks take seriously and adhere to daily. However, since the Bureau’s creation by the Dodd-Frank Act, the Bureau’s UDAAP authority has been largely undefined and closed to input from stakeholders. A clear and defined process created by this legislation will provide guardrails which are needed to ensure that regulated entities know what is or is not permitted and how they can comply.

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