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Checking Account Disclosures
CBA believes that making banking functions transparent and upfront to consumers is a vital part of the bank-consumer partnership. We remain concerned about legislation or regulation that may go too far and actually cause consumers more financial harm than good. For example, a prohibition on overdraft protection programs, or rules so onerous that they act as de facto restrictions, could hurt consumers more than benefit them. CBA stresses improved information to consumers and better financial education.
- June 8, 2017On Thursday, June 8, 2017, CBA and ABA submitted a comment letter in response to the Department of Education’s (DOE) “Request for Information Regarding Disclosures for Student Financial Accounts.” In May the DOE issued the RFI requesting comment on using a model disclosure very similar to that of the recently enacted model short-form disclosure for prepaid cards. In our comment, we strongly...December 19, 2016On Monday, December 19, 2016, in its second action against the company, the CFPB announced a consent order reached with Military Credit Services, LLC (MCS) resulting from alleged improper contractual disclosures. Specifically, the Bureau alleged violations of the Electronic Fund Transfer Act and Truth in Lending Act, and their implementing regulations – E and Z respectively. According to the...March 30, 2016This week, the CFPB indicated credit card issuers will receive an email with updated instructions regarding submission requirements for sending credit card agreements to the Bureau per The Truth in Lending Act and Regulation Z. The one-year reprieve from this requirement now has expired. The CFPB has attempted to alleviate the submission burden by allowing issuers to send webpage links in lieu of...March 17, 2016On Thursday, March 17, 2016, Senators Bernie Sanders (I-VT), Patty Murray (D-WA), and Dick Durbin (D-IL) introduced legislation to expand Servicemembers Civil Relief Act (SCRA) protections. Specifically, the bill would lower the cap on all loan interest rates to three percent for those on active duty. If servicemembers are eligible for hostile fire or imminent danger pay, no interest will be...February 5, 2016Many CBA Members Already Serving Unbanked Earlier this week, in conjunction with a Wednesday field hearing in Louisville, KY, the CFPB made headlines by calling on the nation’s 25 largest banks to offer alternative (i.e. low-cost, no overdraft) checking accounts to consumers. CBA strongly believes all U.S. consumers should have access to checking accounts with upfront fee disclosures and clear...February 4, 2016On Thursday, February 4, 2016, in conjunction with a field hearing held in Louisville, KY, the Bureau sent a letter to the 25 largest retail banks encouraging them to make available and widely market SAFE accounts – basic checking accounts without overdraft, targeted to the underbanked or those consumers who have been denied traditional accounts. The CFPB also issued a bulletin warning...June 12, 2015CFPB Releases Final Larger Participant Rule for Auto Finance Companies On Wednesday, June 10, 2015, the CFPB issued its final larger participant rule for the automobile financing market, as authorized by section 1024 of the Dodd-Frank Act. When the final rule becomes effective, the Bureau will have supervisory jurisdiction over nonbank auto finance companies engaging in at least 10,000 aggregate...June 8, 2015Trade groups representing the banking, credit union and financial services industry are sounding the alarm over a provision in a bill already passed by the Senate that would require them to report information to the Internal Revenue Service on both interest-bearing and non-interest-bearing accounts. In a letter last week to Senate Majority Leader Mitch McConnell, R-Ken., and House Speaker John...May 15, 2015Washington, D.C. (May 15, 2015) – Richard Hunt, President and CEO of the Consumer Bankers Association (CBA), issued the following statement in response to the Department of Education’s new proposed regulations on college campus financial products. “Though today’s proposal seems to have improved from its original form, what is being veiled as pro-consumer reform is far from it and based on little...March 23, 2015At CBA LIVE 2015 Gallup Reveals “Trust, Engagement and Exceptional Omnichannel” Consumer trust in security and technology is key to the adoption of technology channels and digital wallets Consumers “want it all,” with every physical and digital touchpoint important to customer engagement Distribution network and technology lag behind in driving perceived “excellent value”; consumers want a...