Comment Letters

  • February 25, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA)1 appreciates the opportunity to submit comments in response to the proposal issued in conjunction with the January 10, 2013 ability-to-repay/qualified mortgage (QM) final rules (the Proposal). The Proposal includes a request for comment on additional clarifications regarding the inclusion of loan originator compensation within the 3 percent...
  • February 19, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA)1 appreciates the opportunity to submit comments in response to the Consumer Financial Protection Bureau’s (CFPB’s or Bureau’s) request for information (RFI) to study the effect of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) on the credit card market. The CFPB states it will use the information...
  • February 15, 2013
    Dear Ms. Jackson: The Consumer Bankers Association, the American Bankers Association, and the American Bankers Insurance Association (collectively, the “Associations”) appreciate the opportunity to submit comments on the Proposed Policy (“Proposal”) to exempt individual companies, on a case-by-case basis, from current federal disclosure requirements in order to test “trial disclosures.” The...
  • January 15, 2013
    Dear Ms. Jackson: The Clearing House Association L.L.C., the American Bankers Association, the Consumer Bankers Association, The Financial Services Roundtable, the Independent Community Bankers of America, NACHA – The Electronic Payments Association, and the National Association of Federal Credit Unions (collectively, the “Associations”) respectfully submit to the Bureau of Consumer Financial...
  • January 7, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments in connection with the proposal to amend the Credit Card Accountability Responsibility and Disclosure Act of 2009 (Card Act) rules, along with proposed revisions to the applicable official interpretations. Currently, these rules require credit card issuers to consider a consumer’s independent...

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