Comment Letters

  • September 30, 2021
    Dear Chairwoman Khan: The Consumer Bankers Association (“CBA”) appreciates the opportunity to provide our comments in response to the Federal Trade Commission’s (“FTC”) Solicitation for Public Comment on Contract Terms that May Harm Competition (“Solicitation”). In particular, CBA will focus its comments on the reasonable use of non-compete clauses, also known as non-compete agreements...
  • September 24, 2021
    Dear Chairs Yarmuth and Velázquez, and Ranking Members Smith and Luetkemeyer: On behalf of the Consumer Bankers Association (CBA), I am writing to share our concerns with the provision contained within the Committee on Small Business section (Title X, SEC. 100502. FUNDING FOR CREDIT ENHANCEMENT AND SMALL DOLLAR LOAN FUNDING) of the underlying Budget Reconciliation Bill, that would authorize the...
  • September 10, 2021
    The Consumer Bankers Association (“CBA”) appreciates the opportunity to comment on the Consumer Financial Protection Bureau (“CFPB or Bureau”) notice and request for comment regarding electronic disclosure on mobile devices (“Notice”). Since the beginning of the COVID-19 pandemic, we have seen a dramatic shift in consumer confidence in banking through digital channels. This shift in mobile...
  • August 18, 2021
    Dear Representative Luetkemeyer: The undersigned trade associations representing thousands of banks, credit unions, financial institutions, and businesses of all sizes that serve America’s consumers write to express our strong support for H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB)...
  • August 16, 2021
    Dear Chairman Warner and Ranking Member Rubio, In the wake of recent ransomware and other cybersecurity attacks, we appreciate your efforts to improve the resilience of federal agencies and private critical infrastructure, emphasizing the importance of public-private collaboration in this ongoing fight. The financial services sector shares your commitment to cybersecurity and the value in sharing...
  • August 12, 2021
    Dear Ms. Misback: The undersigned trade associations, which represent virtually all the Nation’s regulated financial institutions, write to request that the Board of Governors of the Federal Reserve System (“Board”) withdraw the recent Federal Reserve proposal (“Proposal”) to amend Regulation II (12 C.F.R. Part 235),1 unless it is revised materially in the manner recommended herein. During this...
  • August 9, 2021
    To Whom It May Concern: The Consumer Bankers Association (CBA) is pleased to provide comments in response to your Request for Input (RFI) on Eligibility Requirements for Single Family MBS Issuers. CBA is the only national trade association focused exclusively on retail banking. Established in 1919, the association is now a leading voice in the banking industry and Washington, DC, representing...
  • July 30, 2021
    Ladies and Gentlemen: On behalf of this country’s banks, of all sizes and structures, the undersigned bank trade associations respectfully request that the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the “Agencies”) provide an additional 30 days for interested stakeholders to submit...
  • July 27, 2021
    Dear Chair Warren and Ranking Member Kennedy: On behalf of the Education Funding Committee of the Consumer Bankers Association (CBA), I am writing to share our views for the July 27, 2021 hearing entitled “Protecting Student Loan Borrowers and the Economy in Upcoming Transitions.” We appreciate the Subcommittee’s continued interest in student loan debt and share your concerns about the negative...
  • July 23, 2021
    Dear Chairman Brown and Ranking Member Toomey: The undersigned trade associations, representing depository institutions that serve millions of American consumers, are pleased to share our views on pending legislative measures that propose to limit the fees and interest charged on consumer loans, such as bills that would impose a national “fee and interest rate” cap of 36%. Small dollar loans,...

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