To Whom it May Concern: The Consumer Bankers Association (“CBA”) sends this letter in response to the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) Director Rohit Chopra’s remarks at the White House Roundtable on Protecting Americans from Harmful Data Broker Practices and additional details released on the scope of CFPB’s forthcoming Small Business and Regulatory Enforcement and Fairness Act (“SBREFA”) outline and Notice of Proposed Rulemaking (NPRM) related to data brokers under the Fair Credit Reporting Act (“FCRA”) and Regulation V. CBA understands that, as part of the...
To Whom it May Concern: The Consumer Bankers Association (“CBA”)1 appreciates the opportunity to submit comments2 to the Consumer Financial Protection Bureau (the “Bureau”) in response to the policy statement regarding the prohibition on abusive acts or practices (the “Policy Statement”).3 We would like to thank Director Rohit Chopra for recognizing CBA as a leading voice of the financial services industry in his recent testimony to Congress4 when he repeatedly cited CBA’s response to the Bureau’s 2020 proposed procedural rule on the Advisory Opinion Program.5 As articulated in CBA’s Advisory...
The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau (the Bureau) in response to the notice of proposed rulemaking on credit card penalty late fees (the NPRM). In addition to the comments shared in the letter CBA submitted jointly with several other trade associations, CBA writes separately to express significant concerns with the Bureau’s Dodd-Frank Act section 1022(b) analysis (“1022” or “1022 Analysis”) contained within the NPRM. This comment letter is narrowly focused on addressing the deficiencies in the Bureau’...
CBA Letter to CFPB ahead of "Data Broker" Rulemaking under FCRA