Comment Letters

  • October 20, 2020
    Dear Mr. Feldman: The Consumer Bankers Association (“CBA”) appreciates the opportunity to respond to the Federal Deposit Insurance Corporation’s (“the FDIC” or “the Agency”) notice and request for comment (“the Proposal”) regarding revisions to the agency’s Guidelines for Appeals of Material Supervisory Determinations (“Guidelines”). We applaud the FDIC’s efforts to enhance the independence of...
  • October 1, 2020
    The Consumer Bankers Association welcomes the Consumer Financial Protection Bureau’s (“CFPB’” or “Bureau”) efforts to create a new category for seasoned qualified mortgages (“seasoned QMs”). CBA agrees a seasoned QM definition would complement existing qualified mortgage (“QM”) definitions and help ensure access to responsible, affordable mortgage credit. Furthermore, we also believe the Bureau...
  • September 24, 2020
    Re: Request for Information (“RFI”) on Standard Setting and Voluntary Certification for Models and Third-Party Providers of Technology and Other Services The Consumer Bankers Association (“CBA”) applauds the FDIC’s efforts to promote the efficient and effective adoption of technology at FDIC-supervised banks and to facilitate the supervision of technology usage at these institutions without...
  • September 23, 2020
    September 23, 2020 The Honorable Nydia M. Velázquez Chairwoman Committee on Small Business U.S. House of Representatives 2302 Rayburn House Office Building Washington, D.C. 20515 The Honorable Steve Chabot Ranking Member Committee on Small Business U.S. House of Representatives 2371 Rayburn House Office Building Washington, D.C. 20515 Dear Chairwoman Velázquez and Ranking Member Chabot: On behalf...
  • September 15, 2020
    September 15, 2020 The Honorable Roger Wicker Chairman Committee on Commerce, Science, & Transportation U.S. Senate 512 Dirksen Senate Office Building Washington, D.C. 20510 The Honorable Maria Cantwell Ranking Member Committee on Commerce, Science, & Transportation U.S. Senate 420A Hart Senate Office Building Washington, D.C., 20510 Dear Chairman Wicker and Ranking Member Cantwell: On...
  • September 14, 2020
    INTRODUCTION AND SUMMARY OF ARGUMENT Modern businesses must communicate with their customers in a rapid, efficient manner. This isn’t only because businesses want to provide excellent customer service. Customers expect, and even demand, routine communications like health care appointment reminders, delivery notifications, low-balance alerts, and fraud warnings. Consumers rely on these...
  • September 9, 2020
    Dear Ms. Gardineer and Mr. Nguyen: Thank you for meeting with the Bank Policy Institute and the Consumer Bankers Association (together, the “Associations”) in early Summer to discuss the Office of the Comptroller of the Currency’s May 2020 final rule revising the Community Reinvestment Act regulations. The Associations write to provide the OCC with a set of questions on the final rule on which we...
  • September 9, 2020
    Re: QM Definition Under the Truth in Lending Act (Regulation Z): General QM Loan Definition The Consumer Bankers Association (“CBA”) applauds the Consumer Financial Protection Bureau (“Bureau” or “CFPB”) on its efforts to modify and enhance the definition of the General Qualified Mortgage (“QM”) as defined by Regulation Z’s Ability-To-Repay/Qualified Mortgage (“ATR/QM”) Rule. We appreciate the...
  • August 31, 2020
    The American Bankers Association, ACA International, American Association of Healthcare Administrative Management, American Financial Services Association, Consumer Bankers Association, Credit Union National Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Retail Federation, and Student Loan Servicing Alliance (the Associations)...
  • August 21, 2020
    Ms. Galban: The Consumer Bankers Association (CBA) appreciates this opportunity to comment on the Consumer Financial Protection Bureau’s (Bureau) Proposed Advisory Opinion Program. CBA recognizes much of this program was developed in response to the Bureau’s Request for Information on Bureau Guidance and Implementation Support. CBA responded to the Bureau’s request with a call for the Bureau to...

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