Comment Letters

  • August 6, 2013
    Ladies and Gentlemen: The Financial Services Roundtable, the Consumer Bankers Association, and the American Bankers Association appreciate the opportunity to comment on the request by the Consumer Financial Protection Bureau (the “Bureau”) for information concerning a proposed survey of “consumer awareness of dispute resolution provisions in their agreements with credit card providers,” and “[w]...
  • August 5, 2013
    Dear Director Cordray, The Consumer Bankers Association (CBA), the Education Finance Council (EFC), the National Council of Higher Education Resources (NCHER) and the Student Loan Servicing Alliance (SLSA) are writing to urge the Consumer Financial Protection Bureau (the “Bureau”) to immediately provide private student loan providers with a 30-day compliance grace period for lenders and servicers...
  • August 2, 2013
    Dear Sir or Madam: The undersigned trade associations (the Associations) appreciate the opportunity to offer our views on the advance notice of proposed rulemaking (ANPR) recently issued by the Department of Defense (Department). The ANPR seeks comment on whether the Department should consider revising existing protections under the Military Lending Act which apply to consumer credit extended to...
  • July 29, 2013
    Dear Chairman Rockefeller and Ranking Member Thune: The undersigned organizations, representing the financial services industry, are writing in support of S. 1353, the Cybersecurity Act of 2013, as introduced, and to thank you for your leadership in forging a bipartisan bill. S. 1353 would improve the cybersecurity of our nation in several ways. In particular, it encourages the private and public...
  • July 22, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau (CFPB) in response to the proposed clarifications and revisions to certain of the mortgage rules issued in January of this year. Specifically, these proposed changes and clarifications address: (1) the loss mitigation and error resolution procedures...
  • June 24, 2013
    Dear Chairman Johnson and Ranking Member Crapo: The Consumer Bankers Association (CBA) is Washington’s public policy leader for private student lenders and appreciates the opportunity to share some of our views with the Senate Banking Committee for its hearing entitled “Private Student Loans: A Regulatory Perspective.” CBA’s Education Funding Committee represents all the major bank participants...
  • June 21, 2013
    Amici Curiae AMICI’S INTEREST IN THIS CASE Many of Amici’s members, constituent organizations and affiliates (collectively, “Members”) have independently adopted as standard features of their consumer contracts provisions that call for individual arbitration of disputes arising from or relating to those contracts, upon the election of either party. They use arbitration because it is a prompt,...
  • June 17, 2013
    INTEREST OF AMICI CURIAE The American Bankers Association (“ABA”), headquartered in Washington, D.C., is the principal national trade association of the financial services industry. The ABA’s members, located in each of the 50 states, the District of Columbia, and Puerto Rico, include financial institutions of all sizes. ABA members hold a majority of the domestic assets of the banking industry...
  • June 12, 2013
    Dear Chairman Landrieu and Ranking Member Risch: The Consumer Bankers Association (CBA), the only national financial trade group focused exclusively on retail banking and consumer financial services, writes to you in support of S. 289, the “Commercial Real Estate and Economic Development” (CREED) Act of 2013. CBA applauds your leadership on this legislation, which would extend the low-interest...
  • June 4, 2013
    Dear Secretary Donovan and Director Cordray: The undersigned trade associations (the “Associations”) submit this letter to request written guidance that includes a clear safe harbor from liability in areas where multiple federal mortgage standards conflict. The Department of Housing and Urban Development (“HUD”) recently finalized a regulation under the Fair Housing Act that expressly provides...

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