CBA Comment on CFPB Request for Information Regarding Student Loan Servicing

Dear Ms. Jackson:

The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau’s (CFPB’s or Bureau’s) proposed rule “Defining Larger Participants of the Student Loan Servicing Market,” Docket NO. CFPB-2013-0005. Our comments reflect the view of CBA’s Education Funding Committee. The Committee includes the largest bank lenders of private student loans.

Members of the CBA Education Funding Committee support the Bureau’s initiative to expand supervision of student loan servicing. Because servicers that are banks are already subject to supervision, establishment of supervision over larger non-bank participants in the student loan servicing market is appropriate. Subject to the detailed discussion below, CBA supports the proposed rule as promulgated as a means of accomplishing the objective of CFPB supervision of all major participants in the student loan servicing market.

To read the full Comment Letter, download the PDF.