Comment Letters

  • October 27, 2021
    Dear Senator Scott: On behalf of the Consumer Bankers Association (“CBA”), I write to express our support for S. 3056, the Prohibiting IRS Financial Surveillance Act. This bill is vitally important as lawmakers continue to deliberate proposals that would require banks to provide the IRS with details and data on the accounts of customers who deposit or withdrawal $600 annually. Congress must...
  • October 27, 2021
    Dear Representative Ferguson: On behalf of the Consumer Bankers Association (“CBA”), I write to express our support for H.R.5586, the Prohibiting IRS Financial Surveillance Act. This bill is vitally important as lawmakers continue to deliberate proposals that would require banks to provide the IRS with details and data on the accounts of customers who deposit or withdrawal $600 annually. Congress...
  • October 18, 2021
    Ms. Misback, Mr. Sheesley, and the Chief Counsel’s Office: The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments in response to the proposed interagency guidance and request for comment (Proposed Guidance) issued by the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of...
  • October 4, 2021
    Director Chopra: The Consumer Bankers Association (CBA) congratulates you on your confirmation as the Director of the Consumer Financial Protection Bureau (Bureau). CBA has worked with every Director since the Bureau’s inception to champion the consumer benefits of retail banking and advocate for sound banking policy. CBA welcomes the opportunity to work with you to advance the Bureau’s mission...
  • September 30, 2021
    Dear Chairwoman Khan: The Consumer Bankers Association (“CBA”) appreciates the opportunity to provide our comments in response to the Federal Trade Commission’s (“FTC”) Solicitation for Public Comment on Contract Terms that May Harm Competition (“Solicitation”). In particular, CBA will focus its comments on the reasonable use of non-compete clauses, also known as non-compete agreements...
  • September 24, 2021
    Dear Chairs Yarmuth and Velázquez, and Ranking Members Smith and Luetkemeyer: On behalf of the Consumer Bankers Association (CBA), I am writing to share our concerns with the provision contained within the Committee on Small Business section (Title X, SEC. 100502. FUNDING FOR CREDIT ENHANCEMENT AND SMALL DOLLAR LOAN FUNDING) of the underlying Budget Reconciliation Bill, that would authorize the...
  • September 10, 2021
    The Consumer Bankers Association (“CBA”) appreciates the opportunity to comment on the Consumer Financial Protection Bureau (“CFPB or Bureau”) notice and request for comment regarding electronic disclosure on mobile devices (“Notice”). Since the beginning of the COVID-19 pandemic, we have seen a dramatic shift in consumer confidence in banking through digital channels. This shift in mobile...
  • August 18, 2021
    Dear Representative Luetkemeyer: The undersigned trade associations representing thousands of banks, credit unions, financial institutions, and businesses of all sizes that serve America’s consumers write to express our strong support for H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB)...
  • August 16, 2021
    Dear Chairman Warner and Ranking Member Rubio, In the wake of recent ransomware and other cybersecurity attacks, we appreciate your efforts to improve the resilience of federal agencies and private critical infrastructure, emphasizing the importance of public-private collaboration in this ongoing fight. The financial services sector shares your commitment to cybersecurity and the value in sharing...
  • August 12, 2021
    Dear Ms. Misback: The undersigned trade associations, which represent virtually all the Nation’s regulated financial institutions, write to request that the Board of Governors of the Federal Reserve System (“Board”) withdraw the recent Federal Reserve proposal (“Proposal”) to amend Regulation II (12 C.F.R. Part 235),1 unless it is revised materially in the manner recommended herein. During this...

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