Comment Letters
June 23, 2022Dear Chairwoman Schakowsky and Ranking Member Bilirakis: On behalf of the financial services trade associations listed above, we are pleased to submit these comments regarding the American Data Privacy and Protection Act (ADPPA)(H.R. 8152). Our members are strong proponents of protecting consumer data and privacy and have done so for a very long time because protecting consumer financial data is...
June 21, 2022Dear Mr. Sheesley: We, the undersigned banking trade associations, write to collectively voice our concern with the FDIC’s recent decision to summarily eliminate the Office of Supervisory Appeals (“the OSA”) and reinstate the agency’s Supervision Appeals Review Committee (“the SARC”). The Associations strongly object to the FDIC’s decision on substantive and procedural grounds. Not only do we...
June 13, 2022The Consumer Bankers Association (CBA) writes in opposition to H.R. 4277, the “Overdraft Protection Act”, that would restrict access to a safe emergency liquidity option, which provides a financial safety net for consumers. CBA is the voice of the retail banking industry whose products and services provide access to credit to millions of consumers and small businesses. Our members operate in all...
May 31, 2022Dear Director Chopra, The American Bankers Association and Consumer Bankers Association (the Associations) appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s (Bureau, or the CFPB) procedural rule amending the risk-determination procedures applicable to the Bureau’s exercise of supervisory authority over a nonbank entity that may “pose[] risks to consumers”...
May 31, 2022Dear Mr. Sheesley: The Bank Policy Institute (BPI), the Consumer Bankers Association (CBA) and the Mid-Size Bank Coalition of America (MBCA) submit this letter in response to the March 31, 2022, request of the Federal Deposit Insurance Corporation (FDIC) for “comments regarding the effectiveness of [all aspects of] the existing framework in meeting requirements of . . . the Bank Merger Act.” In...
May 25, 2022Dear Chairwoman Waters and Ranking Member McHenry, The American Bankers Association, Bank Policy Institute, Consumer Bankers Association, Credit Union National Association, National Association of Federally-Insured Credit Unions, National Bankers Association, and The Clearing House appreciate the opportunity to share this letter detailing our views on the topic of Central Bank Digital Currency (...
May 19, 2022Director Chopra: The Consumer Bankers Association (CBA) applauds the decision by the Consumer Financial Protection Bureau (the Bureau) to utilize its dormant authority to examine nonbank financial companies (fintechs) that pose risks to consumers; however, CBA urges the Bureau to further protect consumers by adding markets in which unsupervised nonbanks hold a significant share – including the...
May 4, 2022Statement for the Record On behalf of the American Bankers Association, Bank Policy Institute, Consumer Bankers Association, Credit Union National Association, and National Association of Federally-Insured Credit Unions before the United States Senate Committee on the Judiciary On behalf of their thousands of card-issuing members, the American Bankers Association, Bank Policy Institute, Consumer...
May 2, 2022Dear Chairman Durbin and Ranking Member Grassley, We are writing to express our strong opposition to any expansion of the Durbin Amendment through either antitrust or any other body of law. The Durbin Amendment, passed as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act, imposed a cap on interchange fees for covered banks and credit unions, defined as those with assets of...
CBA Comment Letter re the Postal Non-Banking Financial Services Modernization Pilot Program