Comment Letters
- February 6, 2023Dear Chairman Barr and Ranking Member Foster: The Consumer Bankers Association (CBA) submits this letter for the record for the hearing entitled “Revamping and Revitalizing Banking in the 21st Century.” We appreciate the committee’s continued attention to consumer data privacy and the formation of de novo banks. CBA is the voice of the retail banking industry whose products and services provide...
- January 26, 2023Dear Director Chopra: As the financial services industry awaits the finalization of the Bureau’s rulemaking for Small Business Lending Data Collection under the Equal Credit Opportunity Act (“the Section 1071 Rule”), the Consumer Bankers Association (CBA)1 requests that the Bureau immediately, upon the publication of a final Section 1071 Rule, establish industry-wide working groups and channels...
- January 25, 2023To Whom it May Concern: The Consumer Bankers Association (CBA) appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (the Bureau) Small Business Regulatory Enforcement Fairness Act (SBREFA) outline concerning consumers’ personal financial data rights and the pending rulemaking pursuant to Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act...
- January 25, 2023Ladies and Gentlemen: The undersigned financial services trades welcome the opportunity to comment on the Consumer Financial Protection Bureau’s Outline of Proposals regarding its rulemaking on Personal Financial Data Rights. We jointly write to elevate a necessary and foundational precept in any rulemaking undertaken by the CFPB under section 1033 of the Dodd-Frank Act. Our paramount concern is...
- January 10, 2023Dear Director Chopra, For years banks have been on the front lines fighting fraud and continue to do so in response to increasingly prevalent and sophisticated financial scams across peer-to-peer (P2P) payment platforms. Banks continue to dedicate incredible resources on an annual basis, including billions of dollars each year, to keep consumers and their money safe. Some of these industry...
- January 6, 2023Dear Director Seaborn: The Consumer Bankers Association (CBA) appreciates the opportunity to submit this letter in response to the U.S. Small Business Administration’s (SBA or Agency) request for comments on the SBA’s proposal to lift the moratorium on licensing new Small Business Lending Companies (SBLCs) and add a new type of entity called a Mission-Based SBLC (Proposed Rule). In the Proposed...
- December 23, 2022Dear Administrator Guzman: The signatories on this letter are the leading organizations representing virtually all the lenders participating in the U.S. Small Business Administration (SBA) 7(a) loan program. We are writing to request that you withdraw the two Proposed Rules—the Affiliation and Lending Criteria for the SBA Business Loan Programs, 87 FR 64724 (“Affiliation Proposed Rule”), and the...
- December 9, 2022Dear Chairwoman Waters and Ranking Member McHenry: 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...
- December 9, 2022Dear Chairwoman Waters and Ranking Member McHenry: 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...
Joint Trades Letter on Debit Card Interchange Fees and Routing