Comment Letters

  • February 20, 2024
    The Bank Policy Institute, the American Bankers Association, and the Consumer Bankers Association (together, “the Associations”) appreciate the opportunity to comment on the Department of the Treasury’s Request for Information to help inform its development of a national strategy for financial inclusion as required by The Financial Services and General Government Appropriations Act, 2023. The...
  • February 20, 2024
    The Bank Policy Institute, the American Bankers Association, and the Consumer Bankers Association (together, “the Associations”) appreciate the opportunity to comment on the Department of the Treasury’s Request for Information to help inform its development of a national strategy for financial inclusion as required by The Financial Services and General Government Appropriations Act, 2023. The...
  • February 8, 2024
    In November 2023, the Federal Reserve Board proposed to further reduce debit interchange rates, which could lead to higher costs for consumers.In a recently-published white paper, Nick Bourke, the creator and former Executive Director of Pew Charitable Trusts’ Consumer Finance and Housing program, shows that the Federal Reserve Board’s proposed rule could increase consumers’ costs for checking...
  • February 8, 2024
    PART ONE: CBA Uses CFPB Data to Set Record Straight on CARD Act Report In passing the sweeping reforms of the credit card market under the 2009 Credit Card Accountability Responsibility and Disclosure (“CARD”) Act, Congress required that the Consumer Financial Protection Bureau (CFPB) publish a review of the state of the credit card market every two years. This year’s Consumer Credit Card Market...
  • February 8, 2024
    Regulation II A proposal that would make checking accounts more expensive by cutting debit revenue by a third On October 25, the Federal Reserve Board (the “Fed”) issued a rulemaking that would lower the maximum amount of interchange revenue that most debit card issuers can earn (the “Fee Cap”). This would be the first adjustment of the Fee Cap since it was introduced by a 2011 Fed rulemaking...
  • February 7, 2024
    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...
  • January 31, 2024
    Dear Chairman Brown and Ranking Member Scott: The Consumer Bankers Association (CBA) submits the following comments for the hearing titled “Examining Scams and Fraud in the Banking System and Their Impact on Consumers.” We appreciate the Committee’s attention to these issues. CBA is the voice of the retail banking industry whose products and services provide access to credit to millions of...
  • January 24, 2024
    Executive Summary The Durbin Amendment limits interchange fees that banks charge for processing merchant debit card transactions, requiring them to be “reasonable and proportional” to the card-issuing bank’s costs. The Federal Reserve Board enacted Regulation II in 2011 to enforce the Durbin Amendment. It set fee caps that reduced covered debit interchange fees by more than 40 percent. In...
  • January 24, 2024
    The Consumer Bankers Association (“CBA”) is America’s only member-driven trade association focused exclusively on retail banking.1 Since 1919, CBA has partnered with member banks to promote sound policy, prepare the next generation of diverse bankers to lead the industry, and enable consumers’ individualized approaches to the American dream. In the summer of 2023, our nation’s prudential bank...

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