CBA and ABA Comment on FTC's Proposed Rule on Unfair or Deceptive Fees

To Whom It May Concern:

The American Bankers Association and the Consumer Bankers Association (together, “the Associations”) appreciate the opportunity to comment on the Federal Trade Commission’s (“FTC”) notice of proposed rulemaking (“NPRM”) on Unfair or Deceptive Fees (“the Proposed Rule”). Both the Associations support the FTC’s objective of ensuring that consumers understand the prices and fees associated with products and services that they buy. But the Associations have significant concerns regarding the scope of the Proposed Rule and its potential effects on our members and their customers. The Proposed Rule, as applied to the Association’s members, risks creating substantial confusion about the cost of financial products and exceeds the FTC’s statutory jurisdiction

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