Comment Letters
December 7, 2022To Whom It May Concern: The American Bankers Association (ABA),1 the Consumer Bankers Association (CBA),2 and the Credit Union National Association (CUNA)3 appreciate the opportunity to submit comments to the Consumer Financial Protection Bureau (CFPB) in response to CFPB’s notice and request for additional comments regarding CFPB’s inquiry into big tech payment platforms.4 As we have previously...
December 2, 2022Dear Senator Cardin, Senator Paul, Representative Velázquez, and Representative Luetkemeyer: As the leading organizations representing virtually all of the thousands of lenders participating in the U.S. Small Business Administration (SBA) 7(a) loan program, we write to make you aware of our serious concerns regarding SBA’s recently released Proposed Rules: Affiliation and Lending Criteria for the...
November 21, 2022Dear Mr. Sheesley: We, the undersigned banking trade associations, appreciate the FDIC soliciting further public comment on amendments to its Guidelines of Material Supervisory Determinations (“Guidelines”).In response to the initial feedback collected after the FDIC Board voted to reconstitute the Supervision Review Appeals Committee (“SARC”), the FDIC is proposing to amend its Guidelines of...
October 13, 2022To whom it may concern, The undersigned Associations are submitting this letter to supplement comments submitted to the Federal Deposit Insurance Corporation on August 19, 2022 regarding the notice of proposed rulemaking to increase initial base deposit insurance assessment rates by 2 basis points until the Deposit Insurance Fund (DIF) achieves the FDIC’s long-term goal of achieving a Designated...
October 6, 2022Dear Majority Leader Schumer, Minority Leader McConnell, Speaker Pelosi, Minority Leader McCarthy, Chairman Reed, Ranking Member Inhofe, Chairman Smith, and Ranking Member Rogers: The undersigned state and national trade associations, representing virtually all banks and credit unions, including those primarily serving military-affiliated customers and members, write to express our strong...
September 27, 2022Dear Speaker Pelosi, and Minority Leader McCarthy: The American Bankers Association, Bank Policy Institute, Consumer Bankers Association, Credit Union National Association, Electronic Payments Coalition, Independent Community Bankers of America, National Association of Federally-Insured Credit Unions, and National Bankers Association write to express our strong opposition to the “Credit Card...
September 15, 2022The market for personal loans is massive and growing, yet the fintechs and other non-bank lenders who make such loans are not subject to regular oversight by the Consumer Financial Protection Bureau (CFPB), which has “created an unlevel playing field and a large risk to consumers,” write the Consumer Bankers Association (CBA) and the Center for Responsible Lending (CRL). The groups jointly filed...
August 29, 2022August 29, 2022 Ann E. Misback Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue NW Washington, DC 20551 Re: Regulation Implementing the Adjustable Interest Rate (LIBOR) Act Docket No. R-1775, RIN 7100-AG34 Dear Ms. Misback: The Consumer Bankers Association (CBA)[1] is pleased to submit these comments on the Notice of Proposed Rulemaking (Proposal) by...
August 22, 2022August 22, 2022 Comment Intake – Relationship Banking Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Docket No. CFPB-2022-0040 Re: Comments in Response to Request for Information Regarding Relationship Banking and Customer Service, Docket No. CFPB-2022-0040 To Whom it May Concern: The Bank Policy Institute,[1] the Consumer Bankers Association,[2] and the American...
CFPB Semi Annual Hearing- Letter to Senate Banking Committee