CBA Comment on CFPB's Larger Participant Rule

To Whom It May Concern,

The Consumer Bankers Association (CBA) appreciates the opportunity to provide comment on the Consumer Financial Protection Bureau’s (CFPB or Bureau) Notice of Proposed Rulemaking regarding larger participants in the general-use digital consumer payment application market (Proposed Rule).

I. CBA Strongly Supports Regulation of Nonbanks Engaged in Consumer Financial Services.

CBA understands that the Bureau seeks to establish supervisory authority over certain nonbank covered persons, including financial technology companies (fintechs), in the consumer payment application market offering funds transfer and wallet functionalities through digital applications for consumers’ general use in making payments to other persons for personal, family, or household purposes. CBA strongly believes that consumers benefit from increased market competition, and a level playing field must exist for all entities competing in the same market.

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