Comment Letters
September 10, 2021The Consumer Bankers Association (“CBA”) appreciates the opportunity to comment on the Consumer Financial Protection Bureau (“CFPB or Bureau”) notice and request for comment regarding electronic disclosure on mobile devices (“Notice”). Since the beginning of the COVID-19 pandemic, we have seen a dramatic shift in consumer confidence in banking through digital channels. This shift in mobile...
August 18, 2021Dear Representative Luetkemeyer: The undersigned trade associations representing thousands of banks, credit unions, financial institutions, and businesses of all sizes that serve America’s consumers write to express our strong support for H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB)...
August 16, 2021Dear Chairman Warner and Ranking Member Rubio, In the wake of recent ransomware and other cybersecurity attacks, we appreciate your efforts to improve the resilience of federal agencies and private critical infrastructure, emphasizing the importance of public-private collaboration in this ongoing fight. The financial services sector shares your commitment to cybersecurity and the value in sharing...
August 12, 2021Dear Ms. Misback: The undersigned trade associations, which represent virtually all the Nation’s regulated financial institutions, write to request that the Board of Governors of the Federal Reserve System (“Board”) withdraw the recent Federal Reserve proposal (“Proposal”) to amend Regulation II (12 C.F.R. Part 235),1 unless it is revised materially in the manner recommended herein. During this...
August 9, 2021To Whom It May Concern: The Consumer Bankers Association (CBA) is pleased to provide comments in response to your Request for Input (RFI) on Eligibility Requirements for Single Family MBS Issuers. CBA is the only national trade association focused exclusively on retail banking. Established in 1919, the association is now a leading voice in the banking industry and Washington, DC, representing...
July 30, 2021Ladies and Gentlemen: On behalf of this country’s banks, of all sizes and structures, the undersigned bank trade associations respectfully request that the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the “Agencies”) provide an additional 30 days for interested stakeholders to submit...
July 27, 2021Dear Chair Warren and Ranking Member Kennedy: On behalf of the Education Funding Committee of the Consumer Bankers Association (CBA), I am writing to share our views for the July 27, 2021 hearing entitled “Protecting Student Loan Borrowers and the Economy in Upcoming Transitions.” We appreciate the Subcommittee’s continued interest in student loan debt and share your concerns about the negative...
July 23, 2021Dear Chairman Brown and Ranking Member Toomey: The undersigned trade associations, representing depository institutions that serve millions of American consumers, are pleased to share our views on pending legislative measures that propose to limit the fees and interest charged on consumer loans, such as bills that would impose a national “fee and interest rate” cap of 36%. Small dollar loans,...
July 16, 2021Dear Mr. Sheesley, The Bank Policy Institute and the Consumers Bankers Association (together, the "Associations") appreciate the opportunity to comment on the request for information issued by the Federal Deposit Insurance Corporation seeking input regarding insured depository institutions' current and potential activities related to digital assets. Banks have traditionally been at the forefront...
CBA Comment Letter on 7(a) Direct Lending Provision