Comment Letters

  • September 14, 2020
    INTRODUCTION AND SUMMARY OF ARGUMENT Modern businesses must communicate with their customers in a rapid, efficient manner. This isn’t only because businesses want to provide excellent customer service. Customers expect, and even demand, routine communications like health care appointment reminders, delivery notifications, low-balance alerts, and fraud warnings. Consumers rely on these...
  • September 9, 2020
    Dear Ms. Gardineer and Mr. Nguyen: Thank you for meeting with the Bank Policy Institute and the Consumer Bankers Association (together, the “Associations”) in early Summer to discuss the Office of the Comptroller of the Currency’s May 2020 final rule revising the Community Reinvestment Act regulations. The Associations write to provide the OCC with a set of questions on the final rule on which we...
  • September 9, 2020
    Re: QM Definition Under the Truth in Lending Act (Regulation Z): General QM Loan Definition The Consumer Bankers Association (“CBA”) applauds the Consumer Financial Protection Bureau (“Bureau” or “CFPB”) on its efforts to modify and enhance the definition of the General Qualified Mortgage (“QM”) as defined by Regulation Z’s Ability-To-Repay/Qualified Mortgage (“ATR/QM”) Rule. We appreciate the...
  • August 31, 2020
    The American Bankers Association, ACA International, American Association of Healthcare Administrative Management, American Financial Services Association, Consumer Bankers Association, Credit Union National Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Retail Federation, and Student Loan Servicing Alliance (the Associations)...
  • August 21, 2020
    Ms. Galban: The Consumer Bankers Association (CBA) appreciates this opportunity to comment on the Consumer Financial Protection Bureau’s (Bureau) Proposed Advisory Opinion Program. CBA recognizes much of this program was developed in response to the Bureau’s Request for Information on Bureau Guidance and Implementation Support. CBA responded to the Bureau’s request with a call for the Bureau to...
  • August 19, 2020
    August 19, 2020 The Honorable Steven T. Mnuchin Secretary U.S. Department of Treasury 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 The Honorable Jovita Carranza Administrator Small Business Administration 409 Third Street, SW Washington, D.C. 20416 Dear Secretary Mnuchin and Administrator Carranza: On behalf of the Consumer Bankers Association (CBA) and the International Franchise...
  • August 6, 2020
    To Whom It May Concern: The American Bankers Association (ABA)1 and the Consumer Bankers Association (CBA) are pleased to submit their comments to the Bureau of Consumer Financial Protection (Bureau) on its proposed amendments to Regulation Z (Truth in Lending Act) to address the cessation of the London Inter-Bank Overnight Rate (LIBOR), which is expected to be discontinued after December 31,...
  • August 5, 2020
    Ms. McPartland: The Consumer Bankers Association (CBA) appreciates this opportunity to further comment on the Consumer Financial Protection Bureau’s (Bureau) amendments to the Fair Debt Collection Practices Act (FDCPA), focusing on disclosures of certain time-barred debts. CBA commented thoroughly on other issues related to revisions of the FDCPA during the initial comment period in 2019 and...
  • August 3, 2020
    Dear Acting Comptroller Brooks: The Consumer Bankers Association (“CBA”) appreciates the opportunity to comment on the Office of the Comptroller of the Currency’s (“OCC”) advanced notice of proposed rulemaking (“ANPR”) on digital activities and supports the OCC’s efforts to modernize and promote responsible innovation within the banking system. A modernized banking system has the potential to...
  • August 3, 2020
    August 3, 2020 The Honorable Mike Crapo The Honorable Sherrod Brown Chairman, Committee on Ranking Member, Committee on Banking, Housing and Urban Affairs Banking, Housing and Urban Affairs United States Senate United States Senate Washington, DC 20510 Washington, DC 20510 Dear Chairman Crapo and Ranking Member Brown: As you consider potential financial services provisions for the COVID-19...

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