Comment Letters

  • December 22, 2020
    To Whom It May Concern: The Consumer Bankers Association (CBA) is pleased to submit these comments to the Bureau of Consumer Financial Protection, Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and National Credit Union Administration (together, the “Agencies”) in response to the Notice of Proposed Rulemaking (...
  • December 15, 2020
    Dear Director Kraninger: The Consumer Bankers Association (CBA) greatly appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (“CFPB” or “Bureau”) Small Business Regulatory Enforcement Fairness Act (“SBREFA”) outline concerning the small business lending market and the pending rulemaking pursuant to Section 1071 of the Dodd-Frank Wall Street Reform and Consumer...
  • December 1, 2020
    To Whom It May Concern: The Consumer Bankers Association (“CBA” or “the Association”) appreciates the opportunity to offer comments in response to the Consumer Financial Protection Bureau’s (“CFPB” or “the Bureau” or “the agency”) Request for Information on the Equal Credit Opportunity Act and Regulation B (“the RFI”). We commend the Bureau for soliciting feedback on the Equal Credit Opportunity...
  • November 16, 2020
    To Whom It May Concern: The Bank Policy Institute (“BPI”), the American Bankers Association (“ABA”), the Bankers Association for Finance and Trade (“BAFT”), the Center for Capital Markets Competitiveness (“CCMC”), the Consumer Bankers Association (“CBA”),the Independent Community Bankers of America (“ICBA”), the Institute of International Bankers (“IIB”) and the Securities Industry and Financial...
  • October 26, 2020
    Mr. Smith: The Consumer Bankers Association (CBA) appreciates this opportunity to comment on the Federal Communications Commission’s (Commission) Proposed Rule implementing certain exemptions under the Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED Act). CBA worked with Congress in the drafting of much of the TRACED Act and appreciates this opportunity to further comment...
  • October 20, 2020
    Dear Mr. Feldman: The Consumer Bankers Association (“CBA”) appreciates the opportunity to respond to the Federal Deposit Insurance Corporation’s (“the FDIC” or “the Agency”) notice and request for comment (“the Proposal”) regarding revisions to the agency’s Guidelines for Appeals of Material Supervisory Determinations (“Guidelines”). We applaud the FDIC’s efforts to enhance the independence of...
  • October 1, 2020
    The Consumer Bankers Association welcomes the Consumer Financial Protection Bureau’s (“CFPB’” or “Bureau”) efforts to create a new category for seasoned qualified mortgages (“seasoned QMs”). CBA agrees a seasoned QM definition would complement existing qualified mortgage (“QM”) definitions and help ensure access to responsible, affordable mortgage credit. Furthermore, we also believe the Bureau...
  • September 24, 2020
    Re: Request for Information (“RFI”) on Standard Setting and Voluntary Certification for Models and Third-Party Providers of Technology and Other Services The Consumer Bankers Association (“CBA”) applauds the FDIC’s efforts to promote the efficient and effective adoption of technology at FDIC-supervised banks and to facilitate the supervision of technology usage at these institutions without...
  • September 23, 2020
    September 23, 2020 The Honorable Nydia M. Velázquez Chairwoman Committee on Small Business U.S. House of Representatives 2302 Rayburn House Office Building Washington, D.C. 20515 The Honorable Steve Chabot Ranking Member Committee on Small Business U.S. House of Representatives 2371 Rayburn House Office Building Washington, D.C. 20515 Dear Chairwoman Velázquez and Ranking Member Chabot: On behalf...
  • September 15, 2020
    September 15, 2020 The Honorable Roger Wicker Chairman Committee on Commerce, Science, & Transportation U.S. Senate 512 Dirksen Senate Office Building Washington, D.C. 20510 The Honorable Maria Cantwell Ranking Member Committee on Commerce, Science, & Transportation U.S. Senate 420A Hart Senate Office Building Washington, D.C., 20510 Dear Chairman Wicker and Ranking Member Cantwell: On...

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