Comment Letters
November 27, 2023Dear Chairman McHenry and Ranking Member Waters: The Consumer Bankers Association (CBA) submits the following comments for the hearing entitled “The Semi-Annual Report of the Bureau of Consumer Financial Protection.” We appreciate the committee’s continued oversight of the Consumer Financial Protection Bureau (CFPB or Bureau) and its activities. CBA is the voice of the retail banking industry...
November 17, 2023Dear Director Chopra: On September 15, the Consumer Financial Protection Bureau (CFPB or the Bureau) unveiled potentially sweeping changes to the Fair Credit Reporting Act (FCRA) rules (Regulation V) when it issued its “Outline of Proposals and Alternatives Under Consideration for the Small Business Advisory Review Panel for Consumer Reporting Rulemaking.”1 The undersigned trade associations urge...
November 8, 2023I. EXECUTIVE SUMMARY The Final Rule updates the evaluation framework for banks, with Small Banks defined as those with less than $600 million in assets, Intermediate Banks as those with $600 million to under $2 billion in assets, and Large Banks as those with $2 billion or more in assets. Large Banks are evaluated under the Retail Lending Test, Retail Services and Products Test, Community...
November 8, 2023On October 24, 2023, the OCC, FDIC, and FRB promulgated a finalized CRA modernization rule (the “Final Rule”). In response to a request by the Consumer Bankers Association, the following has been prepared by outside counsel Alston & Bird LLP to provide CBA members with a high-level summary of the Final Rule. Click here for the entire summary
November 6, 2023To Whom it May Concern: The Bank Policy Institute, The Clearing House (TCH), and the Consumer Bankers Association (CBA), appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s (the CFPB) Small Business Regulatory Enforcement Fairness Act (SBREFA) outline concerning consumer reporting (hereinafter “SBREFA outline”). The SBREFA outline represents the first proposed...
October 27, 2023Dear Director Chopra: The American Fintech Council (AFC), the American Bankers Association (ABA), the American Financial Services Association (AFSA), the Bank Policy Institute (BPI), the Clearing House Association, the Community Development Bankers Association (CDBA), the Consumer Bankers Association (CBA), the Credit Union National Association (CUNA), the Electronic Transactions Association (ETA...
October 20, 2023Dear Chair Powell: The undersigned nine trade organizations represent a broad coalition of federally regulated financial institutions, including community banks, credit unions, and military financial institutions who are concerned about regulatory actions impacting the sustainability and affordability of core deposit account services. We write to urge the Board of Governors of the Federal Reserve...
October 6, 2023Dear Director Chopra: The Association of Credit and Collection Professionals (ACA), the American Financial Services Association (AFSA), the American Fintech Council (AFC), The Clearing House (TCH), the Consumer Bankers Association (CBA), the Center for Capital Markets Competitiveness (CCMC), the Consumer Data Industry Association (CDIA), the Electronic Transactions Association (ETA), the...
September 26, 2023Dear Senators Reed and Merkley: The undersigned trade associations, representing financial institutions that serve hundreds of millions of American consumers, are united in opposition to proposals that would limit the fees and interest charged on consumer loans through a national fee and interest rate cap of 36 percent. Small dollar loans, credit cards, and other forms of short term credit are...
CBA Submits Letter to Senate Banking Committee ahead of The Consumer Financial Protection Bureau’s Semi-Annual Report to Congress