Comment Letters

  • July 10, 2023
    SUMMARY OF ARGUMENT: The Bureau’s funding scheme is historically unique—and unconstitutional. The Bureau is endowed with “vast authority.” Seila Law LLC v. CFPB, 140 S. Ct. 2183, 2210 (2020). Its jurisdiction encompasses not only consumer financial-services companies, but also individuals and businesses that engage in any of ten specified consumer financial activities that are common throughout...
  • July 3, 2023
    Dear Director Chopra: The Bank Policy Institute, American Financial Services Association, Consumer Bankers Association, Credit Union National Association, Mortgage Bankers Association, and the U.S. Chamber of Commerce are providing these comments in response to the Consumer Financial Protection Bureau’s Statement of Policy Regarding the Prohibition on Abusive Acts or Practices (Docket No. CFPB–...
  • July 3, 2023
    To Whom it May Concern: The Consumer Bankers Association (“CBA”)1 appreciates the opportunity to submit comments2 to the Consumer Financial Protection Bureau (the “Bureau”) in response to the policy statement regarding the prohibition on abusive acts or practices (the “Policy Statement”).3 We would like to thank Director Rohit Chopra for recognizing CBA as a leading voice of the financial...
  • June 8, 2023
    Dear Chairman Brown and Ranking Member Scott The Consumer Bankers Association (CBA) submits the following comments for the hearing entitled “The Consumer Financial Protection Bureau’s Semi-Annual Report to Congress.” We appreciate the committee’s continued oversight of the Consumer Financial Protection Bureau (CFPB or Bureau) and its activities. CBA is the voice of the retail banking industry...
  • June 8, 2023
    Dear Chairman McHenry and Ranking Member Waters: The Consumer Bankers Association (CBA) submits the following comments for the hearing entitled “The Semi-Annual Report of the Bureau of Consumer Financial Protection.” We appreciate the committee’s continued oversight of the Consumer Financial Protection Bureau (CFPB or Bureau) and its activities. CBA is the voice of the retail banking industry...
  • May 10, 2023
    Dear Chairman Womack and Ranking Member Hoyer: The Consumer Bankers Association (CBA) respectfully submits this letter for the subcommittee’s consideration of fiscal year 2024 Financial Services and General Government (FSGG) appropriations. 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...
  • May 10, 2023
    On behalf of the Consumer Bankers Association (CBA), I write to express our support for S. 1362, the Transparency in CFPB Cost-Benefit Analysis Act. This bill is an important component of CFPB reform and will help ensure the Bureau’s policies are grounded in sound data and evidence. Cost-benefit analysis is an important tool for regulators to use to balance the costs of implementing and complying...
  • May 3, 2023
    The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau (the Bureau) in response to the notice of proposed rulemaking on credit card penalty late fees (the NPRM). In addition to the comments shared in the letter CBA submitted jointly with several other trade associations, CBA writes separately to express significant...
  • April 25, 2023
    Dear Chairman McHenry and Ranking Member Waters: The Consumer Bankers Association (CBA) submits this letter for the committee’s April 26, 2023 markup of bills. We appreciate the committee’s attention to meaningful CFPB reforms to ensure a safe and well-functioning financial services marketplace. CBA is the voice of the retail banking industry whose products and services provide access to credit...
  • April 14, 2023
    Dear Chairman McHenry and Ranking Member Waters: The undersigned trade associations write regarding the increasing threat credit repair scams pose to consumers and the credit markets. 1 Credit repair organizations exploit the most vulnerable Americans and inundate creditors and credit bureaus with meritless and duplicative claims that information in a credit report is inaccurate. These activities...

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