Joint Trades Comment on CFPB's Proposed Larger Participant Rule

Dear Director Chopra:

This letter is submitted on behalf of the American Bankers Association and the Consumer Bankers Association. We appreciate the opportunity to provide comments on the proposed rulemaking Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications issued on November 17, 2023. We are pleased that the Consumer Financial Protection Bureau (CFPB) is establishing supervisory authority over large nonbank providers of general-use digital payment applications. It is essential that the same consumer protections that are provided by banks to their customers be provided by nonbanks to their own customers when those nonbanks offer the same services. Therefore, supervision of consumer protections should be consistent across the industry regardless of whether the provider is a bank or nonbank. CFPB supervision in conjunction with examinations will help to improve consumer protection in what is now an underregulated area.

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