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CBA ABA Online Marketplace Lending
September 30, 2015
Marketplace Lending RFI
U.S. Department of the Treasury
1500 Pennsylvania Ave NW., Room 1325
Washington, DC 20220 Dear Sir or Madam,
The American Bankers Association (ABA)1 and the Consumer Bankers Association (CBA)2 (together, the “Associations”) are pleased to provide the following comments to the United States Department of the Treasury (Treasury) in response to its request for information on Online Marketplace Lending.
Emerging technologies are quickly changing the way financial institutions connect with their consumers enabling them to innovate and offer new products and services. Banks have embraced innovation and continue to do so in order to better serve their consumers. Banks have always led in bringing financial technology to customers. Installing ATM networks allowed customers instant access to their money anywhere in the world. Online banking has made it possible to manage money and pay bills from the comfort of home. Checks can now be deposited by smart phone and are scanned at the point of sale. Even today banks look to leverage the latest technologies to provide products and services that meet the diverse needs of their customers.
Innovation in finance has the potential to add meaningful benefits to consumers and spur economic growth by making capital available to growing small businesses. However, we must take care that this innovation is responsible, and that the benefits outweigh the risks for consumers and businesses. It is noteworthy that a large share of innovation seen today is developing outside of the regulated banking industry. Today, new nontraditional financial services providers have entered this space and are now offering financial services directly to consumers.
The Associations believe that all financial services providers must protect consumers, ensure a level playing field of regulation through uniform supervision and enforcement, and be regulated by activity. Adherence to the following fundamental principles will ensure a strong financial system that best serves the needs of consumers and small businesses across the country...(continue reading)