Comment Letters

  • December 14, 2023
    Dear Congressman Barr: On behalf of the Consumer Bankers Association (CBA), I write to express our support for H.R. 6789, the Rectifying UDAAP Act. Reforming the Consumer Financial Protection Bureau’s (CFPB or Bureau) unfair, deceptive, and abusive acts or practices (UDAAP) authority is critical for ensuring transparency by the Bureau and adherence to high regulatory standards for depository...
  • December 4, 2023
    Dear President Biden: The undersigned organizations write to you today asking for your support in our quest for clear rules of the road in the financial services industry that take into account both the benefits and costs of regulations. Millions of Americans are served by our organizations, which include credit unions, banks, mortgage lenders, auto finance companies, installment lenders, credit...
  • November 27, 2023
    Dear Chairman Brown and Ranking Member Scott: 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 industry...
  • November 27, 2023
    Dear Chairman McHenry and Ranking Member Waters: The Consumer Bankers Association (CBA) submits the following comments for the hearing entitled “The Semi-Annual Report of the Bureau of Consumer Financial Protection.” 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 industry...
  • November 27, 2023
    Dear Director Chopra, We write to you with sincere concerns regarding the narrow compliance window for the Consumer Financial Protection Bureau’s implementation of Small Business Lending Data Collection under the Equal Credit Opportunity Act (ECOA), commonly known as the Section 1071 Rule, and to respectfully request that the Bureau extend the implementation period of this rule. Recently, the U.S...
  • November 17, 2023
    Dear Director Chopra: On September 15, the Consumer Financial Protection Bureau (CFPB or the Bureau) unveiled potentially sweeping changes to the Fair Credit Reporting Act (FCRA) rules (Regulation V) when it issued its “Outline of Proposals and Alternatives Under Consideration for the Small Business Advisory Review Panel for Consumer Reporting Rulemaking.”1 The undersigned trade associations urge...
  • November 8, 2023
    I. EXECUTIVE SUMMARY The Final Rule updates the evaluation framework for banks, with Small Banks defined as those with less than $600 million in assets, Intermediate Banks as those with $600 million to under $2 billion in assets, and Large Banks as those with $2 billion or more in assets. Large Banks are evaluated under the Retail Lending Test, Retail Services and Products Test, Community...
  • November 8, 2023
    On October 24, 2023, the OCC, FDIC, and FRB promulgated a finalized CRA modernization rule (the “Final Rule”). In response to a request by the Consumer Bankers Association, the following has been prepared by outside counsel Alston & Bird LLP to provide CBA members with a high-level summary of the Final Rule. Click here for the entire summary
  • November 6, 2023
    To Whom it May Concern: The Bank Policy Institute, The Clearing House (TCH), and the Consumer Bankers Association (CBA), appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s (the CFPB) Small Business Regulatory Enforcement Fairness Act (SBREFA) outline concerning consumer reporting (hereinafter “SBREFA outline”). The SBREFA outline represents the first proposed...

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