CBA Submits Comments on CFPB's Proposed NSF Rule

To Whom it May Concern:

The Consumer Bankers Association (CBA)1 appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (the CFPB or Bureau) Notice of Proposed Rulemaking on Fees for Instantaneously Declined Transactions 2 (the Proposal or Proposed Rule). Under the Proposed Rule, one-time debit transactions, ATM transactions, and person-to-person transactions would be covered. The Bureau states it has preliminarily concluded that the targeted fees are abusive under the Consumer Financial Protection Act (CFPA) because they represent unreasonable advantage-taking of consumers who lack awareness of the risks, costs, or conditions of a financial service or product.

Click here to read the full letter