Comment Letters

  • August 5, 2022
    To Whom It May Concern: The Consumer Bankers Association (“CBA”) [1] is pleased to submit these comments to the Board of Governors of the Federal Reserve System (“Board”), the Office of the Comptroller of the Currency (“OCC”), and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the “Agencies”) on behalf of its members in response to the Joint Notice of Proposed Rulemaking (“NPR...
  • August 1, 2022
    Ladies and Gentlemen: The American Bankers Association (ABA), Consumer Bankers Association, Credit Union National Association, and National Association of Federally‐Insured Credit Unions (collectively, Associations) welcome the opportunity to comment on the Consumer Financial Protection Bureau’s (Bureau) Advance Notice of Proposed Rulemaking (ANPR) regarding credit card late fees and late...
  • July 25, 2022
    The Consumer Bankers Association (CBA) writes in opposition to H.R. 4277, the “Overdraft Protection Act”, that would restrict access to a safe emergency liquidity option, which provides a financial safety net for consumers. CBA is the voice of the retail banking industry whose products and services provide access to credit to millions of consumers and small businesses. Our members operate in all...
  • July 19, 2022
    Dear Speaker Pelosi and Minority Leader McCarthy: On behalf of the Consumer Bankers Association (CBA), I write in opposition to the “Postal Non-Banking Financial Services Modernization Pilot Program” included in the fiscal year 2023 Appropriations Act for Financial Services and General Government. CBA is the voice of the retail banking industry whose products and services provide access to credit...
  • June 23, 2022
    Dear Chairwoman Schakowsky and Ranking Member Bilirakis: On behalf of the financial services trade associations listed above, we are pleased to submit these comments regarding the American Data Privacy and Protection Act (ADPPA)(H.R. 8152). Our members are strong proponents of protecting consumer data and privacy and have done so for a very long time because protecting consumer financial data is...
  • June 21, 2022
    Dear Mr. Sheesley: We, the undersigned banking trade associations, write to collectively voice our concern with the FDIC’s recent decision to summarily eliminate the Office of Supervisory Appeals (“the OSA”) and reinstate the agency’s Supervision Appeals Review Committee (“the SARC”). The Associations strongly object to the FDIC’s decision on substantive and procedural grounds. Not only do we...
  • June 13, 2022
    The Consumer Bankers Association (CBA) writes in opposition to H.R. 4277, the “Overdraft Protection Act”, that would restrict access to a safe emergency liquidity option, which provides a financial safety net for consumers. CBA is the voice of the retail banking industry whose products and services provide access to credit to millions of consumers and small businesses. Our members operate in all...
  • May 31, 2022
    Dear Director Chopra, The American Bankers Association and Consumer Bankers Association (the Associations) appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s (Bureau, or the CFPB) procedural rule amending the risk-determination procedures applicable to the Bureau’s exercise of supervisory authority over a nonbank entity that may “pose[] risks to consumers”...
  • May 31, 2022
    Dear Mr. Sheesley: The Bank Policy Institute (BPI), the Consumer Bankers Association (CBA) and the Mid-Size Bank Coalition of America (MBCA) submit this letter in response to the March 31, 2022, request of the Federal Deposit Insurance Corporation (FDIC) for “comments regarding the effectiveness of [all aspects of] the existing framework in meeting requirements of . . . the Bank Merger Act.” In...
  • May 25, 2022
    Dear Chairwoman Waters and Ranking Member McHenry, The American Bankers Association, Bank Policy Institute, Consumer Bankers Association, Credit Union National Association, National Association of Federally-Insured Credit Unions, National Bankers Association, and The Clearing House appreciate the opportunity to share this letter detailing our views on the topic of Central Bank Digital Currency (...

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